The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5 million
Please note that the French version of this press release was published on 6 November 2025.
In its decision of 5 November 2025, the Enforcement Committee imposed fines of €300,000, €200,000 and €2 million respectively on Carat GP and its directors, Jimmy Guinet and Sébastien Renaud. It also imposed a permanent ban on Carat GP and Mr Renaud from operating as financial investment advisor, and a 10-year ban from operating as such on Mr Guinet.
The Committee first found that Carat GP did not have a secure archiving system, which was nevertheless necessary for its FIA business, and that it had not complied with its professional obligations as regards its procedural systems for product governance, identifying and managing conflicts of interests, handling complaints, and anti-money laundering and combatting the financing of terrorism (AML/CFT). It also considered that the company had failed in its obligation to draw up documentation in compliance with the regulations. Next, the Committee held that Carat GP had not acted honestly, fairly and professionally, and in the best interests of its clients, on the grounds that one of its managers, Mr Renaud, had taken advantage of his position to propose investments to several clients without documenting them, and that Carat GP had not put in place a system to prevent or detect such behaviour. Finally, it considered that the company had failed to assist the inspection mission with the requisite diligence and honesty.
The breaches found against Carat GP were attributed to its two managers.
In addition, for the first time, the Committee held that the company's directors had committed breaches in their personal capacity. In the case of Mr Renaud, the Committee noted that he had failed to comply with the obligation to undergo annual training, the obligation to act diligently and honestly towards the inspectors, and with the prohibition on receiving funds other than those intended to remunerate its activity, since he had received funds from clients on his personal accounts. In the case of Mr Guinet, the Committee found that he had failed to ensure that Carat GP complied with its obligation to act honestly, fairly and professionally, and in the best interests of its clients, in particular by not taking any steps to prevent Mr Renaud from receiving funds for undocumented investments, such that he had himself breached that obligation.
An appeal may be lodged against this decision.
Appeal lodged by Jimmy Guinet before the Conseil d’Etat against decision SAN-2025-10
Jimmy Guinet has lodged an appeal before the Conseil d’Etat against the Enforcement Committee's decision of 5 November 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.
