AMF France v. Forever Winner International Development Ltd, A and B (insider trading, 2020)

Judgment entered

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On 28 February 2020 the Commission des sanctions found, from a body of circumstantial evidence, that a Hong Kong company, its chief executive and an associate bought Club Méditerranée shares in April and May 2013 using inside information about the coming Fosun and Axa PE takeover bid, and sold on announcement. It fined them EUR 800,000, EUR 1,000,000 and EUR 600,000.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

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Penalty as published

€2.4m

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 28 February 2020. The AMF had opened its inquiry into Club Méditerranée's financial information and shares in August 2013. It worked with Hong Kong and Chinese regulators, and the notifications of grievances, with Mandarin translations, were sent by courier in July 2018. The respondents had not answered the earlier detailed letters.

The notifications alleged that the plan for a takeover bid by Fosun and Axa PE was inside information at the latest by 10 April 2013. Forever Winner International Development Ltd (FWI), run by A, was said to have bought 70,000 shares on 29 and 30 April and 2 May 2013, A personally 79,387 shares between 29 April and 7 May, and B 51,800 shares between 3 and 22 May 2013. All were sold on the announcement day, 27 May 2013, at about EUR 17, for alleged gains of EUR 285,995, EUR 323,941 and EUR 196,095.

There was no direct evidence of tipping. The Commission relied on a body of serious, precise and consistent indications: purchases out of keeping with each person's habits, made shortly before the announcement, professional links between A and B, and B's links to Fosun, and poor explanations. It found B's reason, a holiday at a Club Med village and a press article on Fosun, unconvincing because Fosun had been a shareholder since 2010. It found A's and FWI's reasons, Club Med's growth in China and Fosun's standstill commitment ending in March 2013, did not explain buying in late April and May. It held that only possession of the inside information explained the trades.

It fined B EUR 600,000, A EUR 1,000,000 and FWI EUR 800,000, and ordered publication on the AMF website for five years, non-anonymised.

This record does not show who the source of the information was, and it does not show whether the decision was appealed. The gains cited are the AMF's allegations, not findings.

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. 2020-02-28 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.