AMF France v. Keren Finance, A and B (wash trading, 2018)

Judgment entered

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On 8 November 2018 the Commission des sanctions found that a retired investor and the asset manager running his family fund placed matching orders in a thinly traded Compagnie du Cambodge share on three days in 2015, moving shares between his portfolio and the fund's without any change of beneficial owner. It fined the manager EUR 250,000, the investor EUR 650,000 and the fund manager EUR 20,000.

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

€920k

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 (second section) decided the case on 8 November 2018. The AMF's surveillance team had noticed unusual volumes in Compagnie du Cambodge shares in 2015, and an inquiry was opened in April 2016. The shares trade on compartment A of Euronext Paris with two fixings a day, at 11:30 and 16:30, and are very illiquid.

The notifications alleged that on 10 April, 2 September and 9 and 10 November 2015 the investor A, a retiree, and Keren Finance, the portfolio manager of his family SICAV fund, entered large opposite orders against one another, with the sole purpose of moving shares from A's portfolio to the fund and back with no change of economic owner. B, the fund's private manager, was charged for the sessions of 2 September and 9 and 10 November. A was also accused of aggressive buying and selling to widen the gap between the price at which shares moved into his portfolio and the price at which they went back to the fund.

The Commission found that the orders, which made up a large share of daily volume in a very thinly traded share, were likely to give misleading indications of supply and demand and to suggest more participants than there were, even though they moved the price only modestly. It also found the price-setting limb made out on the facts, such as a buy order placed seconds before a fixing that set the fixing price above the indicative price. It held the orders attributable to Keren Finance because its staff placed them. It found the breach made out for A and the firm on three sequences and for B on two.

It fined Keren Finance EUR 250,000, A EUR 650,000 and B EUR 20,000, and ordered publication on the AMF website for five years, non-anonymised.

This record does not show the monetary effect on the investor of the pricing, and it does not show whether the decision was appealed.

This library tags the matter as wash trading and price manipulation. 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 2 techniques 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.

• Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2018-11-08 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.