AMF France v. X, A, B, Y and Z (insider trading, 2021)

Judgment entered

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On 28 April 2021 the Commission des sanctions found that a shareholder (X) bought over a million shares of an anonymised listed company, W, in March 2015 on the back of board-level information about better-than-announced 2014 results, and that one of its board representatives recommended a share purchase to another investor. It fined five respondents EUR 18.2 million in total, EUR 10 million for X.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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Penalty as published

€18.2m

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 April 2021. The AMF had opened its inquiry into W's financial information and shares in August 2015, and notifications of grievances went in October 2019 to X, Y, Z and two individuals, A and B, who sat on W's board for X. The decision also deals with the legal effect of a partial annulment of a search-and-seizure operation at W's head office in April 2017 on the evidence used.

The notifications alleged that X and A used two pieces of inside information, one on W beating its announced 2014 EBITDA target, the other on an update of its strategic plan that raised financial targets, and that X did not declare its trades. They alleged that A and B recommended to Y or passed to it the EBITDA information, that Y used or tried to use it and did not declare its trades, and that Z bought W shares in a closed period before results.

The Commission found that the information on 2014 results was inside information at the latest by 14 March 2015, when W's chief executive emailed directors a figure for expected EBITDA. It held that A, as a director who received it, and X, which acquired 1,050,000 shares and 30,000 warrants between 16 March and 1 April 2015 on non-discretionary instructions, had used it. It did not find use of the second item of information made out. It found B had recommended that Y invest, relying on indications from a meeting and on the statements of Y's representatives and B himself, but not that he had passed on the information; and it did not find that Y used the information, though it found that Y and X failed to declare trades and that Z bought shares in a closed period in August 2017.

It fined X EUR 10,000,000, A EUR 6,000,000, B EUR 2,000,000, Y EUR 100,000 and Z EUR 100,000, and ordered publication on the AMF website for five years, non-anonymised.

This record does not show the amounts of the gains, how the fines relate to each failing, or whether the decision was appealed.

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. 2021-04-28 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.