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.
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
| 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 ; Virtu Financial Europe Ltd |
| Techniques | Layering |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- €10m
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.
- Layering — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 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.
Related actions
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 |