AMF France v. Jordi Eeman (layering, 2023)

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 2023 the AMF agreed a settlement with the independent trader Jordi Eeman over 30 sequences in 21 shares in 2020 to 2021 in which he allegedly used large orders cancelled unexecuted to move the book; he agreed to pay EUR 150,000.

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

€150k

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 Jordi Eeman, dated 16 November 2023. 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 Eeman, an independent trader operating through a Dutch investment firm, was investigated from January 2021 across 21 shares from January 2018.

The AMF described a layering pattern: large passive orders on the best three limits suggesting strong interest, usually cancelled unexecuted, while he traded the other way once other participants had moved. Of 1,156 sequences identified between 1 January 2020 and 30 April 2021, 30 across 23 stock-days looked potentially manipulative, with a total profit of EUR 51,000.

He said his trading firm had changed its detection procedures and software, that gains could be offset by losses and that the period was Covid-affected. He agreed to pay EUR 150,000 in three instalments over fifteen months.

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 layering, 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 2 techniques 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.

• Layering — see how it works, what statute it engages, and every other action tagged the same way.
• Spoofing — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-11-16 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.