AMF France v. A and B (insider trading, 2019)

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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On 13 March 2019 the Commission des sanctions found that two Zodiac Aerospace executives sold shares they had received under a free-share plan in February 2016, while knowing the group's seats division was performing much worse than the market had been told. It fined them EUR 350,000 and EUR 180,000.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

€530k

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 13 March 2019, after a hearing on 15 February. The AMF had opened its inquiry into Zodiac Aerospace's financial information and shares in December 2015, and notifications of grievances went to A and B in December 2017.

The notifications alleged that A sold 20,050 Zodiac Aerospace shares on 18 February 2016, and B sold 10,000 on 22 February 2016, both from free-share plans, while holding inside information about a very sharp fall in the current operating profit of the group's seats division, which carried heavy weight in the group's operating margin.

The Commission found that from 12 February 2016 the information was precise and likely to move the share price, because it made the announced group margin target extremely unlikely to be met. It found that A, as a member of the wider executive committee on the insiders list with access to monthly divisional reporting, and B, as the seats division's commercial director aware of the costs of keeping customers, held the information and were presumed to have used it. It noted that A's avoided loss was EUR 91,130 against a sale made the day after the group walked back its target, which A did not dispute. It rejected the explanations that the sales were planned or that the group had not blocked B's sale.

It fined A EUR 350,000 and B EUR 180,000 and ordered publication on the AMF website for five years, non-anonymised.

This record does not show whether the decision was appealed, and it does not show B's gain.

This library tags the matter as insider trading. 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.

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

Timeline

1. 2019-03-13 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.