AMF SPOT Inspection Findings on Asset Management Compliance Systems

France AMF News Releases

Published March 31st, 2026

Detected March 31st, 2026

Summary

AMF France published findings from its 2025 SPOT inspection campaign examining asset management companies' compliance and internal control systems. The inspections focused on firms with in-house compliance resources, following a 2020 campaign that examined outsourcing of internal control functions. The findings highlight areas of strength and weakness identified across the inspected firms.

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What changed

The AMF conducted a targeted SPOT inspection campaign in 2025 focusing on asset management companies' organization and effectiveness of compliance and internal control systems. The campaign specifically examined firms with in-house compliance resources, building on prior 2020 work that addressed outsourced internal control arrangements. The AMF assessed how these firms identify and manage risks, prevent regulatory breaches, detect malfunctions, and implement corrective actions.

Asset management companies should review the published findings to understand supervisory expectations and common deficiencies observed during inspections. While this is an informational publication rather than an enforcement action, firms should benchmark their own compliance and internal control systems against the findings. The AMF emphasized that these systems are essential for ensuring regulatory compliance and investor protection in an evolving regulatory environment.

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The Autorité des Marchés Financiers publishes the findings of its SPOT inspections on asset management companies’ compliance and internal control systems
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The Autorité des Marchés Financiers publishes the findings of its SPOT inspections on asset management companies’ compliance and internal control systems
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31 March 2026
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The Autorité des Marchés Financiers publishes the findings of its SPOT inspections on asset management companies’ compliance and internal control systems

As part of its 2025 supervisory priorities, the Autorité des Marchés Financiers (AMF) conducted a SPOT inspection on the organisation and effectiveness of asset management companies' compliance and internal control systems. This campaign followed on from work carried out in 2020 on the outsourcing of internal control and focussed this time on structures that have in-house resources for the compliance function.

In a constantly evolving regulatory environment, asset management companies’ compliance function and internal control systems are essential levers for ensuring compliance with the rules and protecting investors. They help identify and manage risks, prevent regulatory breaches, detect malfunctions, and implement the necessary corrective actions.

The AMF carried out a series of SPOT (Operational and Thematic Supervision of Practices) inspections at five asset management companies with different profiles in terms of size, organisation and strategy. These inspections covered the period from 1 January 2022 to 31 December 2024. The findings of this campaign have helped supplement and enrich analyses carried out in parallel based on responses to a questionnaire sent on 4 August 2025 to around forty other asset management companies.

This work forms part of a Common Supervisory Action (CSA) initiated at European level by the European Securities and Markets Authority (ESMA) in 2025, aimed at verifying, in a harmonised manner, compliance with the applicable rules, and the adequacy of asset management companies’ resources and expertise for carrying out their missions and protecting investors.

Among the issues examined, the AMF made the following observations:

organisation, and human and technical resources dedicated to the compliance and internal control function: all the companies inspected have an identified compliance and internal control function, which is usually entrusted to a Chief Compliance and Internal Control Officer, who has direct access to senior management. The AMF noted that companies may also use an external service provider under an assistance contract to carry out certain permanent control tasks;
control plans governing the conduct of internal controls: these companies exhibit varying levels of maturity. In some companies on the panel, they appear to be insufficiently formalised or do not cover all the material risks. Control methodologies are not always documented in detail, which may limit the traceability of the work carried out;
follow-up on recommendations resulting from internal controls or external audits: sometimes, this is only partial. The AMF reiterates that the effective implementation of the action plans associated with these recommendations is a crucial component of an effective internal control system;
periodic control: the AMF expects an independent periodic control function to be set up at asset management companies with significant assets under management and staff, as well at those with complex activities. When asset management companies choose to delegate the periodic control function to an external service provider or to an entity in their group, the AMF notes that this delegation is governed by a contract or agreement that sets out the level of expertise expected of the parties involved;
reporting to senior management: the AMF notes that the senior managers of all the asset management companies on the panel receive, at least once a year, a report providing an overview of the recommendations issued by internal control;
quality of the regulatory data sent to the AMF: the inspections carried out by the regulator revealed shortcomings in the quality of the regulatory information sent to the AMF, particularly in annual disclosure sheets, despite the senior managers of the companies inspected being involved in the process for validating these documents. These anomalies relate to the controls carried out and their results. The AMF reiterates that the reliability, accuracy and completeness of the data reported are essential for it to perform its supervisory role.
Among the good practices, the AMF identified the following points:
introducing a detailed training plan indicating the target audience and topics covered to which facilitates more effective monitoring employee skills in terms of compliance;
ensuring that the Chief Compliance and Internal Control Officer participates, ex officio member, in decision-making bodies (such as committees dedicated to new products or risk management) and management bodies (such as the Board of Directors), and that they are effectively present at the meetings of these bodies;
asking each operational team to update the risk map, so that this accurately reflects the entity's risk areas;
making senior managers aware of the work done by the Chief Compliance and Internal Control Officer, including the controls carried out, the advice provided and the projects undertaken.
Among the poor practices, the regulator identified the following points:
not including, in the procedure in question, the rules and timetable for the intervention of the compliance team when a new project is being created;
not including the results of recent audits on the same topic when preparing a periodic control report;
entrusting responsibility for a key internal procedure to an external employee.
About the AMF
The AMF is an independent public authority responsible for ensuring that savings invested in financial products are protected and that investors are provided with adequate information. The AMF also supervises the orderly operations of markets. Visit our website: https://www.amf-france.org/en