AMF France v. MND, M. Xavier Gallot-Lavallée and others (insider trading, 2025)

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 July 2025 the Commission des sanctions fined the mountain-infrastructure group MND, its chief executive and eight others a combined EUR 1.89 million, and permanently barred a financial adviser and his firm from advising. It found late disclosure of four items of inside information, and insider dealing, illicit disclosure and tipping around two cable-car contracts in June and August 2020.

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

€1.9m

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 9 July 2025. The respondents include MND, listed on Euronext Growth, and its chairman and chief executive Xavier Gallot-Lavallée; Jacques Simoncini, Mikaël Nacivet, Laurent-Olivier Orset and Huseyin Cetinkaya; the financial adviser Jean-François Bertrand and his firm Cougar Invest; and investors Philippe Gaillard and Harry-Davidson Ayache.

The notifications alleged that MND failed to disclose four items of inside information promptly (the Huy cable-car contract, a EUR 15 million Cheyne Capital loan, a three-year postponement of the Snowland contract and the partial cancellation of the Wanlong contract) and published a misleading half-year report in December 2018. They also alleged that others used or passed on knowledge of the Saint-Denis de La Réunion and Huy cable-car contracts before they were announced.

The Commission upheld the four disclosure failures and the insider-list failure against MND, attributing them to Mr Gallot-Lavallée, and rejected the misleading half-year report charge. It found that Mr Simoncini passed the information to Mr Orset, who used it for himself and others and passed it to Mr Cetinkaya, Mr Bertrand and others, with purchases in June and August 2020 including 781,250 shares by Mr Cetinkaya on 10 June. It found that Mr Bertrand recommended purchases to clients and relatives on the basis of the information, and that Mr Gaillard and Mr Ayache used his recommendations to buy 920,000 and 299,000 shares respectively. It found Cougar Invest in breach of its professional duties as an investment adviser.

The fines were EUR 500,000 on MND, 250,000 on Mr Gallot-Lavallée, 25,000 on Mr Simoncini, 15,000 on Mr Nacivet, 300,000 on Mr Orset, 40,000 on Mr Cetinkaya, 400,000 on Mr Bertrand, 300,000 on Cougar Invest and 30,000 each on Mr Gaillard and Mr Ayache. Mr Bertrand and Cougar Invest were also permanently barred from acting as financial investment advisers.

The record does not show the profits made. The decision notes a separate ruling of the Grenoble court of appeal against Mr Bertrand for breach of trust in March 2025 and holds that it did not cover the same breaches, so no parallel criminal case on these facts is recorded here. It does not show whether any respondent appealed.

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. 2025-07-09 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.