AMF France v. H and J (insider dealing, 2011)

Judgment entered

✓ Checked against the primary document on October 5, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the French decision; an independent second reading of 60 of the AMF records agreed on every field for 54 and on the core fields for 59. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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On 16 September 2011 the Commission des sanctions found that a lawyer at a law firm advising on a planned public offer, and a friend of his, bought shares of the target in the days before the offer was announced, and fined each of them EUR 50,000.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

€100k

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in EUR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The first section of the Commission des sanctions of the Autorité des marchés financiers (AMF) decided on 16 September 2011 the part of a wider insider-dealing case that it had held back in February 2011. The decision is anonymised: the respondents appear as H and J, and the issuer as X2.

The notifications of grievances, sent in February 2010, alleged that H and J had used inside information before the announcement, on 23 September 2008, of a simplified public takeover offer for X2 at a 33.7 per cent premium to the prior close. H was charged over purchases of 2,200 and 5,500 shares on 15 and 16 September 2008 (about EUR 37,268), and J over purchases of 13,669 shares between 15 and 18 September (about EUR 65,201).

H argued that some of the buying was for his assistant's account, which he habitually used, and the Commission ordered further investigation before ruling. After reopening the hearing, it found that H, a lawyer at the firm advising on the offer, had knowingly used information from his firm in breach of its internal ban on dealing in listed securities, and that J had likewise traded with full knowledge of what he was doing. It treated the charges as made out against both.

It fined H and J EUR 50,000 each, EUR 100,000 in total, noting profits that the notification of grievances put at EUR 14,104 for H and EUR 26,540 for J, and ordered publication in anonymised form.

This record does not show how the information reached J, whether either respondent appealed, or the other seven respondents in the earlier decision of 17 February 2011, which is a separate decision.

This library tags the matter as insider trading. The tagging is ours, not the regulator's.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the decision.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2011-09-16 Commission des sanctions decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• AMF decision page
• Decision (PDF, French)

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 5, 2026. submit a correction.