AMF France v. Emmanuel Morin (insider trading, 2018)

Settled

✓ 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 November 2018 the AMF agreed a settlement with Emmanuel Morin, head of MND’s Chinese subsidiary, over share purchases in January 2017 before the announcement of a EUR 110 million framework contract; he agreed to pay EUR 60,000.

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

€60k

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 AMF published an administrative settlement (accord de composition administrative) with Emmanuel Morin, dated 26 November 2018. This is not a contested sanctions hearing. The agreement took effect only once the AMF Collège validated it and the Commission des sanctions homologated it; the document gives the signing date but not the homologation date, so the signing date is used here.

Mr Morin was managing director of the Chinese subsidiary of Montagne et Neige Développement (MND), listed on Euronext Paris, and on its permanent insider list. The AMF alleged that on 26 January 2017 he bought 9,500 MND shares and on 30 January 500 more, knowing of a three-year framework contract worth EUR 110 million to develop the Snowland resort in China, signed on 14 January 2017.

MND announced the contract on 16 February 2017 and the shares rose 92% on the day. He sold his whole position on 17 February, a gain the AMF put at EUR 23,509.

He agreed to pay EUR 60,000 to the Treasury, in instalments. The agreement records that the Parquet national financier told the AMF on 29 June 2018 that it did not wish to bring a prosecution against him for these facts, so no criminal case is stated.

What the record does not show: the agreement describes conduct that the person "could" or "would" have committed, so it records allegations and undertakings, not a finding of breach, and it is not styled as a fine. It does not show whether any later challenge occurred.

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. 2018-11-26 Settlement agreed (homologated by the Commission des sanctions)

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 settlement page
• Settlement (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.