AMF France v. M. A, M. Clément Miserez and M. B (insider trading, 2024)

Judgment entered

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In May 2024 the Commission des sanctions fined Clément Miserez EUR 120,000 for buying shares of a listed acquisition vehicle on 11 June 2020, before its founders announced a takeover bid. It cleared the founder, M. A, and a second buyer, M. B.

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

€120k

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 15 May 2024. The respondents are M. A and M. B, published only by those letters, and Clément Miserez. The issuer is published as X, a special purpose acquisition company created by three founders in 2015 and listed on the professional compartment of Euronext Paris in 2016.

On 22 June 2020 the founders and financial partners announced a bid for X at EUR 12 a share. The notifications alleged that the plan was inside information by 8 June 2020, that M. A passed it to the other two, that M. B bought 5,500 shares on 12 and 17 June, and that Mr Miserez bought 11,495 shares on 11 June.

The Commission held that the information was inside information from 8 to 22 June 2020 and that M. A held it. It found no proof that he passed it on, and no proof that M. B held or used it. It found that Mr Miserez held the information and used it for his purchase of 11 June 2020, noting that his purchases were not shown to be in line with his usual habits.

It put M. A and M. B out of the case and fined Mr Miserez EUR 120,000. The decision was published without anonymisation for Mr Miserez for five years and anonymously for the other two.

The record does not show how Mr Miserez came by the information, whether he appealed, or any criminal case.

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. 2024-05-15 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.