AMF France v. M. Denys Sournac and others (insider trading, 2025)

Dismissed

✓ 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 March 2025 the Commission des sanctions rejected insider dealing and illicit disclosure charges against Medicrea's co-founder and three others over trades before Medtronic's planned takeover of Medicrea in July 2020. It accepted that the information was inside information but found no proof that anyone but the co-founder held it.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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.

What is alleged to have happened

The Commission des sanctions of the AMF, second section, decided the matter on 12 March 2025. The respondents are Denys Sournac, co-founder of the spinal-surgery device maker Medicrea, which was listed on Euronext Growth; Stéphane Reynouard and his company SR Capital; and Patrick Orliange.

The notifications alleged that Medtronic's planned acquisition of Medicrea was inside information from 29 May 2020 and that Mr Sournac, a long-standing friend of Mr Reynouard, passed it on, probably in a telephone call on 2 July 2020. They alleged that Mr Reynouard and SR Capital bought Medicrea shares between 3 and 10 July 2020 and resold them on 15 July, and that Mr Orliange recommended purchases to a third person.

The Commission held that the information was inside information from 29 May 2020 at the latest until 15 July 2020 at 08:30, and that Mr Sournac held it. It held that it had not been shown that he transmitted it, that Mr Reynouard and SR Capital or Mr Orliange held it, or that they used it, so the further charges of onward disclosure and recommendation also failed.

The Commission found none of the charges made out. It put all four respondents out of the case and imposed no sanction, ordering publication without anonymisation.

This record is a dismissal. It does not show whether the AMF college appealed, and it describes no 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. 2025-03-12 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.