France's Financial Markets Authority (AMF) published a synthesis of lessons from its SPOT thematic inspections into the organisation and effectiveness of compliance and internal control arrangements at portfolio management companies. The campaign, conducted under the AMF’s 2025 supervisory priorities and following earlier work on outsourced internal control, focused on firms that have internal resources to perform the compliance function and forms part of the European Securities and Markets Authority’s 2025 Common Supervisory Action. The AMF inspected five asset managers with differing size, organisation and strategy, covering the period from 1 January 2022 to 31 December 2024, and complemented the work with analysis of responses to a questionnaire sent to around 40 other firms. It found that all inspected firms had an identified compliance and internal control function, usually led by a compliance and internal control officer with direct access to senior management, and that some firms use external service providers under assistance contracts for parts of ongoing controls. Control plans showed uneven maturity, with some insufficiently formalised, not covering all significant risks, and with control methodologies not always documented in enough detail to ensure traceability; follow-up of recommendations from internal controls or external audits was sometimes only partial. For periodic control, the AMF expects an independent periodic control function at firms with large assets under management and headcount and complex activities, and noted that delegation to an external provider or group entity was framed by contracts specifying the expected expertise. The regulator also identified deficiencies in the quality of regulatory data submitted to the AMF, particularly in annual information forms, including anomalies relating to controls performed and their results, and reiterated that reliable, accurate and complete data is necessary for effective supervision; it also highlighted observed good and poor practices, including governance involvement of the compliance function and clear new product procedures.
France Autorite des marches financiers 2026-03-31
France's Financial Markets Authority publishes SPOT inspection findings on asset managers’ compliance and internal control frameworks
The France Autorité des marchés financiers published findings from SPOT thematic inspections on the organisation and effectiveness of compliance and internal control at portfolio management companies, conducted under its 2025 supervisory priorities and ESMA’s 2025 Common Supervisory Action. While all inspected firms had an identified compliance and internal control function, the AMF found uneven maturity of control plans, partial follow-up of recommendations, and deficiencies in the quality of regulatory data submitted, particularly in annual information forms, and set expectations for independent periodic control at larger and more complex firms.