AMF France v. X and A (spoofing, 2021)

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 28 May 2021 the Commission des sanctions found that a German trading firm (X) and its trader placed large decoy orders on one side of the Eurex Euro-OAT futures book, then traded on the other side and cancelled the decoys, across 303 sequences between July and October 2015. It fined the firm and the trader EUR 1,200,000 each.

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

€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 (first section) decided the case on 28 May 2021, after a hearing on 7 May. The AMF had opened its inquiry into the Euro-OAT and Mid-Term Euro-OAT futures in February 2017, and notifications of grievances, translated into German, went to X and the individual A in May 2020. Because of Covid-19 travel limits, the hearing with the rapporteur was replaced by written questions. The respondents asked for the case to be put on hold while they challenged the AMF board's decision to send the grievances, a request the Commission refused.

The grievances alleged that between 1 July and 13 October 2015 the respondents placed orders on Eurex in Euro-OAT futures expiring in September and December 2015 that gave false or misleading signals of supply, demand and price in 303 sequences, and that in 207 of them, with trades in the opposite direction, they secured a dominant position in the order book that created unfair trading conditions.

The Commission found that in each sequence the firm's large orders at the best price levels created an imbalance of more than 50 per cent on one side of the book, executed on average only about 3 per cent, and were largely cancelled, while orders on the other side were meant to be filled. It held that the decoys did not reflect real buying or selling interest, shifted other participants' positioning, and in 180 of the 207 sequences brought a total profit of EUR 336,920 to X. It also rejected a challenge to the Commission's jurisdiction over trading done in Germany.

It fined X EUR 1,200,000 and A EUR 1,200,000, and ordered publication on the AMF website for five years, non-anonymised.

This record does not show that A's role was separate from the firm's, since the decision treats them together, and it does not show whether the decision was appealed.

This library tags the matter as spoofing. 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.

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

Timeline

1. 2021-05-28 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.