AMF France v. Nyenburgh Holding B.V. and others (spoofing, 2022)

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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In May 2022 the Commission des sanctions fined a Dutch proprietary trading firm and three traders a combined EUR 780,000 for repeated order-book activity on Euronext Paris shares between 2013 and 2016 that gave misleading signals and built a dominant position. The charge against a fourth company lapsed because it had been wound up.

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

€780k

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, first section, decided the matter on 6 May 2022. The respondents are the Dutch trading firm Nyenburgh Holding B.V. and its director Rob Kamsteeg, the former Tilborg Trading B.V. and its owner Dionisius Van Tilborg, and the trader Diede Van Den Ouden.

The notifications alleged that between March 2013 and December 2016 they had traded a set of Euronext Paris shares in ways likely to give false or misleading signals about supply, demand or price, and had secured a dominant position creating unfair trading conditions. Their method turned on passive orders, visible in the order book, that were cancelled quickly.

The Commission found that the cancelled-order indicators were established across 1,099 sequences charged against Nyenburgh and Mr Kamsteeg, that the orders were concentrated in short windows, and that the position-reversal indicator failed for sequences lasting over 15 minutes. It held the misleading-signals and dominant-position breaches proved against Nyenburgh, Mr Kamsteeg, Mr Van Tilborg and Mr Van Den Ouden. It accepted the argument that Tilborg Trading could not be sanctioned after its liquidation on 18 September 2020.

The Commission imposed fines of EUR 200,000 on Nyenburgh, EUR 100,000 on Mr Kamsteeg, EUR 400,000 on Mr Van Tilborg and EUR 80,000 on Mr Van Den Ouden, and ordered publication without anonymisation.

The record does not name the individual issuers, quantify any trading profit, or show whether any respondent appealed. It does not describe any criminal case.

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. 2022-05-06 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.