AMF France v. EcoR1 Capital LLC and M. Oleg Nodelman (marking the close, 2024)

Judgment entered

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In December 2024 the Commission des sanctions fined a San Francisco biotech fund manager EUR 7 million and its founder EUR 3 million for selling Innate Pharma shares in the closing auctions of five sessions in October 2019, which set the price of a Nasdaq offering, and fined the firm for failing to declare crossing the 5 percent threshold.

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

€10m

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 decided the matter on 13 December 2024. The respondents are EcoR1 Capital LLC, a San Francisco investment adviser managing funds that held Innate Pharma shares, and its founder and main shareholder, Oleg Nodelman.

On 7 October 2019 Innate Pharma announced a Nasdaq offering priced on the volume-weighted average of its closing prices on Euronext Paris on 10, 11, 14, 15 and 16 October 2019. The notifications alleged that EcoR1 sold shares at the close on those days, fixing the price at an artificial level, achieving a dominant position and misleading investors, and that it failed to declare threshold crossings in January and October 2019.

The Commission found the manipulation proved on the basis of the price-fixing and closing-time rules, and rejected the separate dominant-position charge. It rejected the argument that only orders entered during the closing phase counted, since transactions executed in the closing fixing are covered too, and it noted that the broker had simply carried out EcoR1's precise instructions. It also found the threshold-crossing breach against EcoR1.

It fined EcoR1 EUR 7,000,000 and Mr Nodelman EUR 3,000,000, EUR 10,000,000 in total, and ordered publication without anonymisation.

The record does not show the price effect in euros, EcoR1's gain or loss, whether the decision was appealed, or any criminal case.

This library tags the matter as marking the close. 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.

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Timeline

1. 2024-12-13 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.