AMF France v. Bourse Direct and A (layering, 2014)

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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In October 2014 the AMF Commission des sanctions fined a day trader, published as A, 75,000 euros for layering-type manipulation across 202 trading sequences, and fined his broker Bourse Direct 250,000 euros for weak controls.

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

€325k

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 2nd section of the Commission des sanctions heard the case on 17 September 2014 and decided it on 1 October 2014. The AMF's board had sent notifications of grievances on 9 April 2013 to an individual investor, published as A, and to the online broker Bourse Direct.

A was a day trader who traded almost every day between July 2010 and September 2012. The AMF alleged that he breached the ban on price manipulation through order-book strategies of the kind known as layering, in which large passive orders are placed on one side of the book while he traded on the other, and that he posted false information on a financial forum. It alleged that Bourse Direct lacked an adequate compliance function and procedures to detect manipulative orders, and failed to report suspected market abuse.

The Commission found that, of 602 stock-day sequences in which A traded, 202 were manipulative, with a net gain of about 311,000 euros on those sequences, and it noted that the AMF's Secretary General had warned him in July 2009 to respect the rules. It did not maintain the suspicious-transaction reporting charge against Bourse Direct, which the Collège's representative had dropped at the hearing, but sanctioned the broker for the other failings. It imposed 250,000 euros on Bourse Direct and 75,000 euros on A, a total of 325,000 euros.

The record does not show how the Commission treated the forum postings, and it does not show whether the decision was appealed, because the document does not say.

This library tags the matter as layering. 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.

• Layering — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2014-10-01 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.