The AMF Enforcement Committee fines eight individuals and two legal entities a total of €1,890,000 for late disclosure of inside information, insider dealing, and breaches of professional obligations
In its decision of 9 July 2025, the Enforcement Committee imposed a fine of €500,000 on MND (formerly Montagne & Neige Développement) and €250,000 on its director for breaches of the obligation to disclose inside information as soon as possible. It also imposed fines ranging from €15,000 to €400,000 on seven other individuals and one legal entity for breaches of insider dealing rules. Among these, a financial investment advisor and their manager were also penalised for failing to comply with professional obligations and were permanently prohibited from working as financial investment advisors.
MND is a company specialising in the development, planning and safety of skiing areas, leisure sites and mountain infrastructure. At the relevant time, it was listed on Compartment C of Euronext Paris and then on Euronext Growth.
The Enforcement Committee found that between 2017 and 2020, MND had failed to comply with its obligation to disclose, as soon as possible, four pieces of inside information relating to the progress and financing of several ski resort design and infrastructure projects. The Committee held that these breaches were attributable to Xavier Gallot-Lavallée, in his capacity as director of MND.
The Enforcement Committee also found that seven individuals -Jacques Simoncini, Mikaël Nacivet, Laurent-Olivier Orset, Huseyin Cetinkaya, Jean-François Bertrand, Philippe Gaillard and Harry-Davidson Ayache- and one legal entity, Cougar Invest, acting as financial investment advisor, had committed breaches of insider dealing rules based on two pieces of inside information relating to MND projects in which some of these people had participated.
In addition, the Committee held that MND had not complied with its obligations relating to keeping and updating insider lists for these two pieces of inside information.
Finally, the Committee found that Cougar Invest, acting as a financial investment advisor, had breached its professional obligations in connection with the advisory services it provided regarding MND shares in 2020, and that these breaches were attributable to its director, Jean-François Bertrand.
An appeal may be lodged against this decision.
Appeal lodged by MND and Mr Xavier Gallot-Lavallée the Paris Court of Appeal against decision SAN-2025-06
MND and Mr Xavier Gallot-Lavallée have lodged an appeal before the Paris Court of Appeal against the Enforcement Committee's decision of 9 July 2025.
Appeal lodged by Cougar Invest and Jean-François Bertrand before the Conseil d’Etat against decision SAN-2025-06
Cougar Invest and Jean-François Bertrand have lodged an appeal before the Conseil d’Etat against the Enforcement Committee's decision of 9 July 2025.
Application for a stay of enforcement lodged by Mr. Jean-François Bertrand before the Conseil d'Etat against the decision SAN-2025-06
Mr Jean-François Bertrand has lodged an application for a stay of enforcement before the Conseil d’Etat against the decision of the Enforcement Committee of 9 July 2025.
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.
