AMF France v. A, B, C, D, Verneuil et Associés, Verneuil Participations, Foch Investissements, FD Conseils et Participations and Duc SA (insider dealing and ownership disclosure failures, 2013)

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 25 July 2013 the Commission des sanctions found that an executive of a listed holding company passed word of an imminent sale of five Vietnamese hotels to an investor who bought 118,604 shares, avoiding about EUR 430,000, and that a group acting in concert had crossed disclosure thresholds and filed accounts late. It fined nine respondents EUR 1.99 million in total.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

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Penalty as published

€2m

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 25 July 2013. The decision names the companies; the individuals are anonymised as A (chairman and chief executive of the listed company), B (its deputy chief executive), and C and D.

Électricité et Eaux de Madagascar (EEM) was a holding company listed on Euronext Paris with stakes in property, hotels, timber, wine and other businesses. A and B, through personal holding companies, jointly controlled Verneuil et Associés and so Verneuil Participations, a shareholder in EEM. The notifications of grievances, sent in April 2012, alleged that A, B and their companies acting in concert had crossed the one-third voting threshold in EEM without declaring it and without launching a bid, that Verneuil Participations published its accounts late, that C used inside information about EEM's coming sale of five Vietnamese hotels to Thien Minh by buying 118,604 EEM shares between 4 June and 24 August 2010, and that B and D passed it to him.

The Commission found concerted action and the threshold failures, the late publication of annual and half-year accounts, and the insider dealing and its transmission. It found that B, in charge of the hotel sale, passed the information to C outside his normal duties while seeking financing to buy A's stake, and that D, who was to receive a success fee of EUR 300,000, passed it on knowing it was inside information. It put C's saving at about EUR 430,000.

It fined C EUR 1.3 million, B EUR 250,000, D EUR 200,000, Verneuil Participations EUR 150,000, A EUR 50,000, and each of Foch Investissements, FD Conseils et Participations, Verneuil et Associés and Duc SA EUR 10,000, EUR 1,990,000 in total, and ordered publication.

This record does not show whether the decision was appealed or whether the amounts changed. Most respondents were sanctioned for ownership-disclosure failures, not for insider dealing, which concerned three individuals.

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. 2013-07-25 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.