Market Manipulation. Search

AMF France v. A and B (false information about a bank's capital, 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 7 November 2013 the Commission des sanctions found that a retired finance professor and a US fund manager spread false information in August 2011, at the height of rumours about Société Générale, that its Tier 1 capital ratio was about 2 rather than the 9.3 per cent it reported. It fined them EUR 10,000 and EUR 8,000.

The record

Structured fields for this action, as recorded in our case library.
Agency AMF (France)
Release number SAN-2013-24
Date filed 2013-11-07
Date resolved 2013-11-07
Court Commission des sanctions (AMF, France)
Status judgment
Asset class equities
Instruments Société Générale shares
Venue Euronext Paris
Criminal parallel No
Defendants A (individual) ; B (individual)
Techniques False rumours

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
€18k

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 7 November 2013, with neither respondent attending the hearing or answering the grievances. The decision is anonymised: A is a retired French university professor of financial analysis who runs several blogs, and B is a US fund manager who runs a blog and a website.

On 3 August 2011 Société Générale reported a Tier 1 ratio of 11.3 per cent and a Core Tier 1 ratio of 9.3 per cent. In the following days rumours about the bank's solvency, including a press report of a risk of failure, disturbed the market. On 11 August the AMF banned net short positions in several French bank shares. The notifications of grievances alleged that on 14 August 2011 A published a blog article, picked up on B's blog and website, saying that treating a balance-sheet line of hybrid instruments as debt rather than equity put the bank's leverage at 50 times and its Tier 1 at 2 per cent.

The Commission found that the figure was inaccurate: it rested on a calculation A had devised, which ignored the regulatory treatment of those instruments, and that A knew or should have known it was inaccurate. It found that B, who relayed the article, was liable too, taking into account A's strong encouragement. It noted that the rumours at the time made the breach graver, but that A did not aim to move the price, which had already hit its low on 10 August.

It fined A EUR 10,000 and B EUR 8,000, EUR 18,000 in total, and ordered publication.

This record does not show whether the decision was appealed, whether either respondent held positions in the shares, or the market effect of the articles.

This library tags the matter as false rumors. 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.

Timeline

  1. 2013-11-07 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.

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

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

Action Agency Filed Technique Penalty Status
SEC v. Milan V. Patel (false rumors, 2025) SEC 2025-04-11 False Rumors — judgment
SEC v. Milan Patel (false rumors, 2023) SEC 2023-02-16 False Rumors — judgment
SEBI v. Ishita Guha (alleged misleading merger news report, 2022) SEBI (India) 2022-10-31 False Rumors — dismissed
SEC v. Charles Parrino (false rumors, 2022) SEC 2022-09-28 False Rumors — settled
SEBI v. Bhavin Pradyumna Pandya and Rakesh Natavarlal Bhatt (bulk SMS and website tips, Global Infratech and Finance, 2022) SEBI (India) 2022-09-23 False Rumors — judgment
SEBI v. Roshan Kumar Arun Mandal and Ajay Dhirajlal Nathwani (bulk SMS tips and circular trades, Mohit Industries, 2022) SEBI (India) 2022-08-25 False Rumors , Matched Orders — judgment

Record added October 5, 2026. submit a correction.