AMF France v. ADT, Lado, Y, Z, C, D, A and B (insider dealing and disclosure failures, 2013)

Judgment entered

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On 5 June 2013 the Commission des sanctions found that the main shareholder of the listed property company ADT sold about 124 million shares through Lado in 2009, after its main tenant gave notice, avoiding a loss estimated at EUR 514,203. It fined him EUR 500,000, Lado EUR 100,000, ADT EUR 50,000 and its chief executive EUR 20,000, and cleared the auditors.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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Penalty as published

€670k

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 5 June 2013. The decision is anonymised: D is the reference shareholder of ADT, Lado is the company through which he held his stake, C was ADT's chairman and chief executive, and Y, Z, A and B are two audit firms and their signing partners.

ADT held and managed property assets and was listed on Euronext Paris. The notifications of grievances, sent in December 2011, alleged that ADT and C disclosed late the notice given by its main tenant, which they knew of from 7 October 2008 and revealed only on 31 August 2009, and that the 2008 and half-year 2009 accounts did not reflect the departure. They alleged that D used the information by selling 124,126,851 ADT shares through Lado between 7 January and 21 July 2009, saving EUR 514,203, and that Lado breached its threshold-crossing and managers' transaction disclosure duties.

The Commission upheld the late-disclosure grievance against ADT and C, and the insider-dealing and disclosure grievances against D and Lado. It found that Lado used share options not meant to be exercised to hide a large disinvestment until 28 July 2009, and that D, who had already been sanctioned in 2007 for misleading information, was a primary insider. It rejected the accounting grievances against ADT and C, finding the valuation choices reasonable though optimistic, and the grievances against the auditors, and put them out of the case.

It fined D EUR 500,000, Lado EUR 100,000, ADT EUR 50,000 and C EUR 20,000, EUR 670,000 in total, and ordered publication anonymising those cleared.

This record does not show whether the decision was appealed. The Commission treated the share sales as insider dealing, not manipulation, despite the earlier tag.

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. 2013-06-05 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.