AMF France v. A, B and X (misleading information and insider trading, 2008)

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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On 4 December 2008 the Commission des sanctions found that a listed oil company and two executives had misstated its acquired oil reserves in June 2005 and that its chief executive at the time had sold 1,435,450 shares knowing the release was wrong. It imposed penalties of EUR 300,000 on the company, EUR 200,000 on the head of its management board and EUR 1.5 million on the former chief executive.

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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Penalty as published

€2m

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 first section of the Commission des sanctions decided this matter on 4 December 2008, after an investigation opened in November 2005 and notifications of grievances sent on 6 February 2008. The issuer, called X, is an independent oil exploration and production company listed on Eurolist; the respondents were X itself, A (its chief executive at the time of the facts) and B (chairman of its management board).

In June 2005 X bought oil assets in Colombia and Venezuela for USD 460 million and announced on 10 June that it had become one of Europe's largest listed independents, with 459 million barrels of proved and probable reserves. On 26 October 2005 it said reserves were 310 million barrels and that expected net profit was EUR 100 million rather than EUR 205 million; the share fell 25.57 per cent the next day. The AMF alleged that the 10 June release included third-party and state reserves and was inaccurate, and that A had sold shares while holding that knowledge.

The Commission found that the information in the 10 June and 26 October 2005 releases was not accurate, precise and sincere, and that reserves and production cost are essential to an oil company's disclosures. It found that the fact the 10 June release was wrong was inside information and that A could not have been unaware of it. A sold 1,435,450 shares for EUR 25,877,373. A said a discretionary manager decided the sales, but the Commission found the mandate set the percentage to keep and the time horizon and that A had given instructions, so it did not break the link.

It imposed financial penalties of EUR 300,000 on X, EUR 200,000 on B and EUR 1,500,000 on A (EUR 2,000,000 in all). For A it said the profit could not be calculated exactly but was substantial.

This record does not show whether the decision was appealed. The decision publishes the company only as X.

This library tags the matter as insider trading (the same decision also sanctions false or misleading information). 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. 2008-12-04 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.