The French Financial Markets Authority (AMF) published findings from thematic SPOT inspections on how asset management companies verify and assess employees’ knowledge and competencies, and updated its guidance to clarify expectations for internal knowledge verification. The revised doctrine tightens requirements around firms’ internal exams so they are applied with the same level of rigor and quality as the external AMF exam delivered by AMF-certified providers. The reviews covered the period from 1 January 2021 to 20 February 2025 and assessed five asset managers with assets under management ranging from over EUR 500 million to over EUR 150 billion. While AMF exam arrangements were generally well documented, the AMF found internal verification frameworks could be less demanding, including lower internal pass thresholds than those set for the AMF exam and insufficiently specified exam modalities in contracts with providers or internal procedures. For broader evaluation of knowledge and competencies, the AMF observed significant differences in formality and expectations between firms and recurring difficulty in distinguishing the separate obligations of knowledge verification (minimum regulatory knowledge for certain key functions) versus knowledge and competence evaluation (qualifications and experience for staff interacting with clients). The inspections also identified persistent shortcomings in anti-money laundering and counter-terrorist financing training, including over-reliance on e-learning without assessing effectiveness, training not tailored to firm-specific risks, and unclear training frequency, alongside better practices such as monitoring tools and reminder systems; sustainable finance training showed more structured approaches, with specialist “sustainable finance” contacts and AMF sustainable finance exam success now mandatory for some staff. The updated AMF position (DOC-2009-29) will apply from 1 January 2026.

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