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

Report an error in this record (amf-fr-san-2021-13-insider-trading-2021) by email

On 9 July 2021 the Commission des sanctions found that the finance director of a listed company (B) unlawfully disclosed results information to an investor (A) before it was published in October 2017 and April 2018, and that A traded on it for himself and for family members. It fined B EUR 500,000 and A EUR 1,000,000, but did not find a third, June 2018 item to be inside information.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

Penalty as published

€1.5m

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 9 July 2021, after a hearing on 25 June. The AMF had opened its inquiry into the shares of a company anonymised as X in July 2018, and notifications of grievances went to B and A in June 2020.

The notifications alleged that B, the finance director of X and so a primary insider, unlawfully disclosed to A the inside information that X published on 18 October 2017 and 18 April 2018 on revenue growth and an upward revision of its EBITDA margin forecast, and a further item published on 13 June 2018 on an expected fall in the margin. A was alleged to have bought or sold X securities for himself and for third parties between 10 and 18 October 2017, on 17 and 18 April 2018, and from 5 to 7 June 2018.

The Commission found that the October 2017 and April 2018 information was inside information, that neither X nor analysts had precisely anticipated it, and that the information published on 13 June 2018 did not have all the features of inside information, so the charges on that item failed. For the rest it relied on a body of serious, precise and consistent indications: a plausible route of transmission, since A had followed and invested in a company where B had previously worked; telephone contact between the two shortly before the suspicious trades; family accounts that all originated with A; the timing of trades; and unconvincing explanations. It held A, an experienced investor, could not have been unaware that the information was inside information.

It fined B EUR 500,000 and A EUR 1,000,000 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 the profits made.

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. 2021-07-09 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.