AMF France v. X, Y, A (insider trading, 2009)

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 December 2009 the AMF's Commission des sanctions fined the chairman of a listed company's supervisory board 1.5 million euros and his family holding company 300,000 euros for insider dealing ahead of a simplified takeover bid, for undeclared trades and for misstating the concert's shareholding. The listed company itself was cleared.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

—

Total relief

—

Alleged gain

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Penalty as published

€1.8m

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 Autorité des marchés financiers (AMF, France) heard the case on 17 December 2009 and decided the same day. The notifications of grievances, sent in January 2009, went to the listed company X, to the family holding company Y and to M. A, who chaired X's supervisory board and ran Y.

The case concerned a simplified public takeover bid (OPAS) at 18 euros a share, a 34 per cent premium, announced on 4 June 2007 by Y acting with the founding family and the company's chief executive, with the aim of delisting X. The notifications alleged that A bought X shares between 13 March and 7 May 2007, after Y had mandated a bank to prepare the bid, while holding inside information about it; that as chairman he had failed to declare his trades in X shares between 1 June 2006 and 7 May 2007; and that he and Y had given the market inaccurate figures for the concert's holding (16,036,293 shares) and the family's purchases in the previous twelve months. X was accused of repeating the inaccurate figures in its response document.

The Commission upheld the breaches against A and Y. It treated the failure to declare trades and the misstatements about holdings as particularly serious because they occurred during a takeover bid and could have affected the protection of minority shareholders and the market's view of whether a squeeze-out would happen. For A it fixed the penalty at the statutory ceiling of 1.5 million euros, noting an economic benefit it assessed at 500,460 euros from the insider dealing, and it imposed 300,000 euros on Y. It put X out of the case.

This record does not show how the penalty was split between the individual breaches, whether the decision was appealed, or the identities of the companies, which are anonymised. The decision reasons about the insider dealing and the misstatements together, and both elements are tagged here.

This library tags the matter as insider trading and misleading issuer disclosure. 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.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.
• Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2009-12-17 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.