AMF France v. A (layering, 2018)

Judgment entered

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On 2 May 2018 the Commission des sanctions found that a Portugal-based proprietary day trader manipulated prices in French-listed shares between 2013 and 2015 by placing large passive buy orders that he cancelled after selling into the price rise, in 208 identified sequences. It fined him EUR 400,000.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

€400k

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 Commission des sanctions of the Autorité des marchés financiers (first section) decided the case on 2 May 2018. A, a Portuguese resident who traded daily for his own account on Euronext through two Portuguese online platforms, did not attend the rapporteur's interview. The AMF had opened its inquiry in February 2015 after unusual activity by a Portuguese bank in French stocks, and the notification of grievances was served through the Portuguese regulator in February 2017.

The single grievance alleged that between 11 November 2013 and 29 September 2015 he manipulated prices in 31 securities listed on Euronext Paris. The alleged method had phases: aggressive buy orders that pushed the best bid and offer up, large passive buy orders placed at the best limits, sell orders at the higher price, and cancellation of the passive orders shortly after the final sale.

The Commission examined 208 selected sequences. It found that in each of them his passive buy orders at the two best limits were larger than any other participant's, made up at least a third of the order volume, and unbalanced the order book, and that each was followed by an opposite-way sell order, with cancellation within five minutes of the last sale in 139 of them. It held that this gave a false impression of buying demand (208 sequences), set prices at an artificial level (158 sequences) and gave a fictitious image of the market (139 sequences), rejected his argument that the orders were legitimate market practice, and held that any intent requirement was met.

It fined A EUR 400,000 and ordered publication on the AMF website for five years in non-anonymised form.

This record does not show his profit, 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

1. 2018-05-02 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.