The AMF Enforcement Committee clears three individuals and one legal entity for insider dealing breaches

Please note that the French version of this press release was published on 14 March 2025

Mr Sournac was accused of having transmitted to Mr Reynouard and Mr Orliange information relating to the proposed acquisition of Medicrea, which was a listed company at that time, by Medtronic. Mr Reynouard, SR Capital, of which he is the director, and Mr Orliange were accused of having improperly used this information to acquire Medicrea shares. Mr Reynouard and Mr Orliange were also accused of having, respectively, transmitted this information and recommended the acquisition of shares on the basis of that same information.

The Committee first considered that the information in question was an inside information on 29 May 2020 at the latest and remained so until 15 July 2020, the date of the press release published by Medicrea to announce the signing of an agreement for the acquisition of its shares by Medtronic through of a takeover bid.

For each of the respondents, the Committee then examined all the indicators relating to the existence of plausible channels for transmitting the inside information, the atypical nature of the disputed orders and the methods used to place them at the opportune time, as well as the explanations adduced by the respondents to justify their transactions. The Committee considered that only some of these indicators have been verified and that these were not sufficient to demonstrate that only the possession of the inside information in question could explain the transactions made by Mr Reynouard, SR Capital and Mr Orliange. Consequently, the Committee considered that they could not be accused of having used this information nor, in the case of Mr Reynouard and Mr Orliange of having transmitted it or recommended the acquisition of shares on the basis of this information.

As regards Mr Sournac, who was found to be in possession of inside information, the Committee therefore considered that he could not be accused of having transmitted this information to them.

Finally, it ordered the publication of the decision without anonymisation.

An appeal may be lodged against this decision.

About the Enforcement Committee
The Enforcement Committee, which is made up of judges and professionals, has total freedom to make decisions. It can impose sanctions on any person or company whose practices contravene laws and regulations that fall within the jurisdiction of the AMF. It ratifies settlement agreements signed by the Secretary General and respondents. And it takes part in the AMF’s educational efforts by clarifying financial regulations when explaining its decisions.