AMF France v. X, Y, Z and others (wash trading, 2021)

Judgment entered

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In August 2021 the Commission des sanctions found that two asset-management companies, a broker and three individuals had traded Euro Stoxx 50 futures in ways that produced wash trades, a manipulation by fictitious device, and sanctioned them, with total fines of EUR 37.02 million and two ten-year bans. The Commission rejected the separate charge of fixing the price at an artificial level, finding the market impact unproven.

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

€37m

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 AMF, sitting in its second section, heard the matter on 7 July 2021 and decided it on 4 August 2021. The respondents are published only as X, Y and Z (three companies) and M. A, M. B and M. C (three individuals).

The notifications of grievances, sent in June 2020, alleged that in 49 identified sequences the respondents had fixed the price of the Euro Stoxx 50 future at an abnormal or artificial level and given a fictitious picture of the market. They also alleged a long list of related failings: weak market-abuse detection, unreported suspicious orders, harm to the interests of fund holders, order-recording and allocation failures, conflicts of interest, and front-running of pending orders for other funds.

The Commission found that an overlay trading pocket run for two diversified funds had placed matching buy and sell orders on the future that met each other, so that no change of beneficial owner occurred. It treated the wash trades as established across the 40 phases of activity investigators had identified, and held that manipulation by fictitious device or artifice was made out against all six respondents. It did not accept the charge of fixing the price at an abnormal level, because the prosecution had not shown an impact on a deep, heavily arbitraged market that was large or lasting enough. It nonetheless upheld the charges of failing to report suspicious orders, harming fund holders through after-the-event allocation of orders, defective order records and front-running by X, among others.

The Commission imposed fines of EUR 25 million on X, EUR 7 million on Y, EUR 5 million on Z and EUR 20,000 on M. C, and warnings on X and Y. It banned M. A from individual and collective portfolio management for ten years and M. B from receiving and transmitting orders, for third parties and on own account, for ten years. The record's penalty figure is the sum of the four fines.

The record does not show the identities behind the anonymised letters, the funds' losses or any gain, or whether the decision was later challenged in court. It does not describe any criminal case.

This library tags the matter as wash 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.

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

Timeline

1. 2021-08-04 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.