Market Manipulation. Search

AMF France v. Euronext Paris SA and Virtu Financial Europe Ltd (layering, 2015)

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 December 2015 the AMF Commission des sanctions fined the market operator Euronext Paris and the algorithmic trader Virtu Financial Europe 5 million euros each, over Virtu's high-volume order-book strategy in 2009 and 2010 and Euronext's discretionary exemption from its order-to-trade ratio.

The record

Structured fields for this action, as recorded in our case library.
Agency AMF (France)
Release number SAN-2015-20
Date filed 2015-12-04
Date resolved 2015-12-04
Court Commission des sanctions (AMF, France)
Status judgment
Asset class equities
Instruments Euronext 100 shares
Venue Euronext Paris
Criminal parallel No
Defendants Euronext Paris SA (entity) ; Virtu Financial Europe Ltd (entity)
Techniques Layering

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
€10m

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 full Commission des sanctions decided this case on 4 December 2015. The AMF's board had notified grievances on 13 January 2014 to the market operator Euronext Paris SA and to the trading firm Virtu Financial Europe Ltd, formerly Madison Tyler Europe (MTE), whose algorithmic trading on Euronext Paris was investigated.

The AMF alleged that Virtu placed orders giving misleading indications of supply, demand or price and held a dominant position in the order book that created unfair trading conditions for others, in breach of the ban on price manipulation, and that it generated a number of order-book interventions out of all proportion to its trades. It alleged that Euronext failed to act neutrally by discretionarily granting one member, MTE, an exemption from the daily ratio of 100 orders to one trade between March 2009 and June 2010, which spared MTE penalties estimated at 19.16 million euros, and that a delay of a few milliseconds between the order-confirmation feed and the market feed benefited MTE.

The Commission sanctioned both companies. It fixed the sanction for each breach at 5 million euros and noted that MTE's activity as an Euronext member produced an estimated profit of 782,000 euros over the period. It imposed 5,000,000 euros on Euronext Paris and 5,000,000 euros on Virtu Financial Europe, a total of 10,000,000 euros.

The record does not show the detailed legal reasoning on each count, and it does not show whether the decision was appealed.

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.

Timeline

  1. 2015-12-04 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
AMF France v. Jordi Eeman (layering, 2023) AMF (France) 2023-11-16 Layering , Spoofing — settled
SEBI v. Nimi Enterprises and others (order-book spoofing, 2023) SEBI (India) 2023-04-28 Spoofing , Layering — judgment
SEC v. Vali Management Partners (Avalon FA Ltd), Nathan Fayyer and Sergey Pustelnik (layering, 2022) SEC 2022-06-17 Layering , Spoofing $22.5m judgment
SEC v. Aleksandr Milrud (layering, 2022) SEC 2022-01-26 Layering — judgment
SEC v. Xuepeng Xie (layering, 2021) SEC 2021-09-27 Layering , Spoofing $600k settled
SEC v. J.P. Morgan Securities LLC (layering and spoofing, 2020) SEC 2020-09-29 Layering , Spoofing $25m settled

Record added October 5, 2026. submit a correction.