What Happened
In July 2025, France’s markets regulator, the Autorité des marchés financiers (AMF), hit Montagne & Neige Développement (MND) and a group of individuals and firms with fines totalling €1.89 million. The case centred on delays in disclosing key information about ski-resort development projects and the misuse of confidential details for trading.
MND itself was fined €500,000 for holding back four pieces of inside information between 2017 and 2020. Its then-director personally received a €250,000 penalty. A further seven individuals and one company, Cougar Invest, were fined between €15,000 and €400,000 for insider trading. Cougar Invest and its director were also banned permanently from acting as investment advisers.
The Questions
The case boiled down to a few key issues:
- Did MND meet its duty to disclose inside information "as soon as possible"
- Did the individuals and Cougar Invest trade or advise based on inside information?
- Were insider lists kept properly and up to date?
- Did the advisers live up to the professional standards expected of them?
The Rules at Play
The EU’s Market Abuse Regulation (Regulation (EU) No 596/2014) requires issuers to disclose inside information without delay to maintain market integrity and investor confidence. It also obliges issuers to maintain insider lists, identifying all persons with access to such information. MAR further prohibits insider dealing and unlawful disclosure, while national regulators like the AMF have authority to sanction both issuers and individuals for breaches. Professional service providers are bound by additional conduct rules requiring diligence, independence, and avoidance of conflicts of interest.
How the AMF Applied Them
The AMF found that MND withheld material information about the financing and progress of its ski-resort development projects, which should have been disclosed under MAR. By delaying disclosure, MND deprived investors of timely knowledge that could influence investment decisions.
Several individuals, as well as Cougar Invest, used this confidential information to carry out transactions in MND securities. This conduct fell squarely within the MAR definition of insider dealing. The AMF also determined that MND’s failure to maintain and update insider lists undermined transparency and regulatory monitoring.
Finally, Cougar Invest and its director were found to have breached their professional obligations by advising clients on the basis of inside information. This justified both financial penalties and permanent exclusion from licensed advisory roles.
Key Lessons
The decision highlights the continuing vigilance of the AMF in enforcing MAR obligations. The key lessons are clear: issuers must disclose inside information without delay; insider lists must be accurate and regularly updated; advisers must ensure that professional conduct standards are met at all times; and individuals cannot avoid liability for insider dealing even if they are not corporate officers.
Beyond the financial penalties, the reputational impact and professional bans underline the seriousness with which regulators treat both disclosure failures and misuse of confidential information. For companies, especially those outside the financial sector, the case demonstrates that obligations apply broadly wherever investor interests may be affected.
