AMF finds compliance gaps in 5 management companies

A Themed Inspection Campaign Coordinated at the European Level

As part of its 2025 supervisory priorities, the AMF conducted SPOT (Supervision of Operational and Thematic Practices) inspections with five asset management companies of varying profiles, covering the period from January 1, 2022, to December 31, 2024. This campaign targets firms with internal resources dedicated to compliance functions and follows the work carried out in 2020 on outsourcing internal control. The findings from these inspections were supplemented by a questionnaire sent on August 4, 2025, to around forty other asset management companies. These efforts are part of a common supervisory action (CSA) initiated at the European level by ESMA in 2025.

Observations and Identified Practices

The AMF noted that all the companies under review have an identified compliance function, typically led by a manager with direct access to senior executives. However, the maturity levels of control plans are inconsistent, with some companies having plans that are not sufficiently formalized or that fail to cover all significant risks.
The follow-up on recommendations from internal controls is sometimes incomplete. The AMF also identified deficiencies in the quality of regulatory data submitted, particularly in the annual information sheets.
Good practices highlighted include the implementation of a detailed training plan, the participation of the compliance manager in decision-making bodies, regular updates of risk mapping by operational teams, and educating executives about the compliance manager's actions.