AMF Expands Reach of Updated Ethics Code for France’s Asset Management Industry

Key Takeaways

• Updated Ethics Framework Approved: The AMF approved the revised “Provisions” section of the AFG’s code of ethics for third-party asset management on May 7, 2026.
• Broader Industry Application: The updated rules now apply to all investment services providers engaged in third-party asset management activities, including firms that are not members of the AFG.
• Expanded Scope Since 2009: The revised code incorporates regulatory developments introduced since the original 2009 framework and now covers all collective investments.
• AML/CFT Oversight Clarified: Investment services providers that are not asset management companies remain subject to AML/CFT supervision under the ACPR rather than the AMF.
• Professional Rules Backed by Enforcement Powers: The approved “Provisions” section continues to carry regulatory weight, allowing the AMF to issue injunctions or sanctions against AFG members that fail to comply.

Deep Dive

France’s financial markets authority is expanding the reach of a long-standing ethical framework for the asset management sector, a move that reflects how regulatory expectations around governance and professional conduct have evolved since the framework was first introduced more than 15 years ago.

The Autorité des Marchés Financiers announced Thursday that it has approved an updated version of the “Provisions” section of the code of ethics published by the Association Française de la Gestion d’Actifs, known as the AFG, and extended its application to all investment services providers engaged in third-party asset management activities, including firms outside the association’s membership.

The revised framework, now titled the “code of ethics for third-party asset management,” updates a document first introduced in 2009 to establish ethical principles for firms managing collective investment schemes and individual investment mandates.

At the time, the AMF approved the “Provisions” section of the code as a recognized set of professional rules. That approval gave the regulator authority to pursue enforcement action, including injunctions and sanctions, against AFG member firms that failed to comply with the provisions.

The regulator also moved in 2009 to extend the framework beyond AFG membership after consulting the Association Française des Etablissements de Crédit et des Entreprises d’Investissement under procedures set out in the AMF General Regulation.

The newly updated version reflects regulatory developments introduced since that original framework was adopted and broadens the document’s scope to cover all collective investments.

While the announcement published Thursday confirms the AMF Board’s approval of the revised provisions, the underlying decision to extend their application to non-AFG member investment services providers dates back to July 4, 2025. According to the AMF, that decision was made pursuant to Articles 314-2, 318-2 and 321-99 of the AMF General Regulation after obtaining a favorable opinion from the AFECEI.

The extension applies to investment services providers engaged in asset management on behalf of third parties, including firms involved in collective investment management and portfolio management for third parties.

The updated framework does, however, draw a clear jurisdictional line around anti-money laundering and counter-terrorist financing obligations.

For investment services providers that are not asset management companies, the AML/CFT provisions contained in the code will not fall under AMF oversight because the regulator does not hold supervisory authority over those market participants in that area. Instead, those firms are expected to follow the applicable requirements overseen by the Autorité de Contrôle Prudentiel et de Résolution, France’s prudential supervision authority.

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