AMF France v. B, Saint Olive Gestion, Archos, A and company X (insider dealing, 2013)

Judgment entered

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On 13 February 2013 the Commission des sanctions found that a portfolio manager at Saint Olive Gestion sold 300,000 Archos shares for clients the day before a private placement was announced, after being told of it under a confidentiality undertaking. It fined him EUR 25,000 with a warning and the firm EUR 50,000, and cleared Archos, its chief executive and the placement bank.

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

€75k

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 second section of the Commission des sanctions of the Autorité des marchés financiers (AMF) decided the case on 13 February 2013. Archos, its chief executive A, Saint Olive Gestion and the manager B are named; the placement bank appears as company X.

The notifications of grievances alleged, first, that in a first capital increase in late 2009 Archos, A and X had left out of the offering note and press release of 26 November 2009 that A had given his subscription rights free to institutional investors who had committed to subscribe, and that this was misleading information. They alleged, second, that B used inside information about a private placement of 1,780,000 Archos shares at EUR 3.50, announced on 30 April 2010, when he sold shares on 29 April, and that Saint Olive Gestion was answerable for him.

The Commission rejected the grievances about the 2009 operation, finding the omitted detail was not something the offering note had to contain and could not have misled investors, and put Archos, A and X out of the case. On the placement, it found that B, a portfolio manager who had signed a confidentiality undertaking on 27 April 2010, agreed on 29 April at 13:30 to subscribe 339,000 shares at EUR 3.50 for about fifteen clients, and from 13:31 sold 300,000 of them on the market at an average EUR 4.7561, a gain of EUR 376,830 for the clients. It held the information was precise and non-public.

It imposed a warning and a EUR 25,000 fine on B and a EUR 50,000 fine on Saint Olive Gestion, EUR 75,000 in total, and ordered publication, with X anonymised.

This record does not show whether the decision was appealed, or what became of the clients' gains.

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. 2013-02-13 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.