AMF France v. A (insider dealing (recommending trades), 2013)

Judgment entered

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On 16 April 2013 the Commission des sanctions found that the head of an investment bank, who advised the biotech company Transgène, recommended that two acquaintances sell their Transgène shares while he knew Roche was terminating a drug licence. It fined him EUR 200,000.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

€200k

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 the case on 16 April 2013. The decision is anonymised: the respondent appears as A, the chairman of an investment bank operating in France that advised Transgène.

Transgène, a biopharmaceutical company listed on Euronext Paris, had an exclusive licence with Roche for its TG4001 product. In late 2010 Roche decided that the partnership was not worth continuing and began renegotiating its terms with a view to ending it. After talks failed, Roche notified Transgène of the termination on 17 February 2011. The notification of grievances, sent in August 2012, alleged that A, who knew of the decision through his advisory role, had recommended that C and D sell their Transgène shares.

The Commission found that the information was inside information that A held in the course of his duties, that he recommended that two people sell before it was public, and that one of them sold in a way that, in its view, only the recommendation could explain, given other evidence of calls and the absence of a serious analysis behind the sale. It treated the breach as committed twice and with full knowledge.

It fined A EUR 200,000, assessing the amount by the gravity of the breach rather than by the losses the recipients avoided, and ordered anonymised publication.

This record does not show whether the decision was appealed, the size of the avoided losses, or the identity of the two recipients, who were not respondents.

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. 2013-04-16 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.