Kbi Global Investors (North America) Ltd.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE SA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.

This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/19/2015
 Exact
 Explanation
If not exact, provide explanation:
DATE ACTION INITIATED IS NOT AVAILABLE, SO DATE OF ORDER IS LISTED
4.
Docket/Case Number:
15-028-B-FB
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Banking Products (Other than CD(s))
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CRÉDIT AGRICOLE SA (CASA) AND ITS SUBSIDIARY CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) HAVE REACHED AGREEMENTS WITH
THE U.S. AND NEW YORK AUTHORITIES THAT HAVE BEEN CONDUCTING INVESTIGATIONS REGARDING U.S. DOLLAR TRANSACTIONS BETWEEN 2003 AND
2008 SUBJECT TO U.S. ECONOMIC SANCTIONS AND CERTAIN RELATED NEW YORK STATE LAWS. CACIB AND CASA, WHICH COOPERATED WITH THE U.S.
AND NEW YORK AUTHORITIES IN CONNECTION WITH THEIR INVESTIGATIONS, HAVE AGREED TO PAY A TOTAL PENALTY AMOUNT OF $787.3MM. THE
PAYMENT OF THIS PENALTY WILL BE ALLOCATED TO THE PRE-EXISTING RESERVE THAT HAS ALREADY BEEN TAKEN AND WILL NOT AFFECT THE
ACCOUNTS FOR THE SECOND HALF OF 2015. THE AGREEMENTS WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (FEDERAL
RESERVE) AND THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) ARE WITH CASA AND CACIB. THE AGREEMENT WITH THE OFFICE
OF FOREIGN ASSETS CONTROL (OFAC) OF THE U.S. DEPARTMENT OF THE TREASURY IS WITH CACIB. CACIB ALSO ENTERED INTO SEPARATE DEFERRED
PROSECUTION AGREEMENTS (DPAS) WITH THE UNITED STATES ATTORNEY'S OFFICE FOR THE DISTRICT OF COLUMBIA (USAO) AND THE DISTRICT
ATTORNEY OF THE COUNTY OF NEW YORK (DANY), THE TERMS OF WHICH ARE THREE YEARS. THE USAO AND DANY HAVE AGREED TO TAKE NO FURTHER
ACTION AGAINST CACIB, CASA, OR ANY OF CACIB'S SUBSIDIARIES OR AFFILIATES REGARDING THE CONDUCT SUBJECT TO THIS INVESTIGATION IF
CACIB COMPLIES WITH ITS OBLIGATIONS UNDER THE DPAS. ON OCTOBER 19, 2018, THE UNITED STATES DISTRICT COURT OF COLUMBIA ENTERED A
FINAL ORDER DISMISSING WITH PREJUDICE THE INFORMATION THAT THE USAO FILED IN 2015 IN CONNECTION WITH THE AGREEMENTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):

10/19/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 787,300,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
NO ADDITIONAL DETAILS ARE AVAILABLE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CIVIL ORDER AND SANCTIONS OF $787.3 MILLION

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE SA
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE CORPORATE

AND INVESTMENT BANK
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
EUROPEAN COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
NONE
3.
Date Initiated (MM/DD/YYYY): 
12/20/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NUMBER AT .40346
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
CREDIT AGRICOLE CORPORATION AND INVESTMENT BANK (CACIB) & CREDIT AGRICOLE S.A. (CASA)
6.
Principal Product Type:
Other
Other Product Types: 
SUPRA-SOVEREIGN, SOVEREIGN AND AGENCY BONDS (OR SSA BONDS)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE EUROPEAN COMMISSION ANNOUNCED ON DECEMBER 20, 2018 THAT IT REACHED A PRELIMINARY VIEW THAT CERTAIN BANKS HAVE BREACHED EU
ANTITRUST RULES. THE ALLEGATIONS RELATE TO THE TRADING OF USD-DENOMINATED SOVEREIGN, SUPRA-SOVEREIGN, AND AGENCY ("SSA") BONDS
ON THE SECONDARY MARKET BETWEEN JANUARY 2013 AND MARCH 2015. CACIB AND CASA HAVE RECEIVED A STATEMENT OF OBJECTIONS FROM THE
EUROPEAN COMMISSION. THE EUROPEAN COMMISSION'S PRESS RELEASE IS AVAILABLE HERE: HTTP://EUROPA.EU/RAPID/PRESS-RELEASE_IP-18-
6895_EN.HTM. CACIB AND CASA ARE CONSIDERING THE STATEMENT OF OBJECTIONS AND WILL HAVE AN OPPORTUNITY TO RESPOND. WE WILL
PROVIDE FURTHER UPDATES AS NECESSARY. UPDATE AS OF MAY 2021: AS WE PREVIOUSLY INFORMED YOU WHEN CASA AND CA-CIB RECEIVED A
STATEMENT OF OBJECTIONS IN DECEMBER 2018, THE SUBJECT MATTER OF THE INVESTIGATION, AND NOW THE DECISION DATED 4/28/21 IMPOSING A
EURO 3,993,000 (OR USD 4,821,966.77) FINE ON CACIB, RELATES TO THE TRADING OF US DOLLAR DENOMINATED SSA BONDS ON THE SECONDARY
MARKET. THE DURATION OF CASA AND CACIB'S PARTICIPATION IN THE ALLEGED CONDUCT IS BETWEEN JANUARY 2013 AND MARCH 2015. CASA AND
CACIB ARE CONSIDERING THE DECISION CAREFULLY, AND ARE ACTIVELY CONSIDERING AN APPEAL. UPDATE AS OF AUGUST 2021: CASA AND CACIB
FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND THE PENALTY IMPOSED, ON JULY 7, 2021.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
APPEALED TO THE EUROPEAN COMMISSION ON JULY 7, 2021.

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
04/28/2021
 Exact
 Explanation
If not exact, provide explanation:
N/A
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,821,966.77
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE EUROPEAN COMMISSION ANNOUNCED ON DECEMBER 20, 2018 THAT IT REACHED A PRELIMINARY VIEW THAT CERTAIN BANKS HAVE BREACHED EU
ANTITRUST RULES. THE ALLEGATIONS RELATE TO THE TRADING OF USD-DENOMINATED SOVEREIGN, SUPRA-SOVEREIGN, AND AGENCY ("SSA") BONDS
ON THE SECONDARY MARKET BETWEEN JANUARY 2013 AND MARCH 2015. CACIB AND CASA HAVE RECEIVED A STATEMENT OF OBJECTIONS FROM THE
EUROPEAN COMMISSION. THE EUROPEAN COMMISSION'S PRESS RELEASE IS AVAILABLE HERE: HTTP://EUROPA.EU/RAPID/PRESS-RELEASE_IP-18-
6895_EN.HTM. CACIB AND CASA ARE CONSIDERING THE STATEMENT OF OBJECTIONS AND WILL HAVE AN OPPORTUNITY TO RESPOND. WE WILL
PROVIDE FURTHER UPDATES AS NECESSARY. UPDATE AS OF MAY 2021: AS WE PREVIOUSLY INFORMED YOU WHEN CASA AND CA-CIB RECEIVED A
STATEMENT OF OBJECTIONS IN DECEMBER 2018, THE SUBJECT MATTER OF THE INVESTIGATION, AND NOW THE DECISION DATED 4/28/21 IMPOSING A
EURO 3,993,000 (OR USD 4,821,966.77) FINE ON CACIB, RELATES TO THE TRADING OF US DOLLAR DENOMINATED SSA BONDS ON THE SECONDARY
MARKET. THE DURATION OF CASA AND CACIB'S PARTICIPATION IN THE ALLEGED CONDUCT IS BETWEEN JANUARY 2013 AND MARCH 2015. CASA AND
CACIB ARE CONSIDERING THE DECISION CAREFULLY, AND ARE ACTIVELY CONSIDERING AN APPEAL. UPDATE AS OF AUGUST 2021: CASA AND CACIB
FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND THE PENALTY IMPOSED, ON JULY 7, 2021. UPDATE AS OF
JULY 2,2024: THERE IS NO UPDATED RULING ON THE CASE. DECISION FROM THE EUROPEAN COMMISSION IS EXPECTED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE SA
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE CORPORATE
AND INVESTMENT BANK
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
EUROPEAN CENTRAL BANK
2.
Principal Sanction:
Other
Other Sanctions: 
ADMINISTRATIVE FINE ONLY
3.
Date Initiated (MM/DD/YYYY): 
07/16/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) & CREDIT AGRICOLE S.A. (CASA)
6.
Principal Product Type:
Other
Other Product Types: 
VARIOUS BANKING PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THIS PENALTY WAS IMPOSED FOR BREACH OF THE PROCEDURE LAID DOWN IN ARTICLE 26(3) OF REGULATION (EU) NO 575/2013 OF THE EUROPEAN

PARLIAMENT BY CLASSIFYING CAPITAL INSTRUMENTS AS COMMON EQUITY TIER 1 INSTRUMENTS DURING THREE (FIVE FOR CASA) CONSECUTIVE
QUARTERLY REPORTING PERIODS AND TWO (THREE FOR CASA) PUBLIC DISCLOSURES IN 2015 AND 2016 WITHOUT THE PRIOR PERMISSION OF THE
COMPETENT AUTHORITY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
07/16/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,600,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ADMINISTRATIVE PENALTY ON CREDIT AGRICOLE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CREDIT AGRICOLE SA (CASA) AMOUNTING TO
EUR 300,000 AND 4.3M RESPECTIVELY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE EUROPEAN CENTRAL BANK (ECB) DECIDED ON JULY 16, 2018 TO IMPOSE AND ADMINISTRATIVE PENALTY ON CREDIT AGRICOLE CORPORATE AND
INVESTMENT BANK (CACIB) AND ITS PARENT, CREDIT AGRICOLE SA (CASA), AN AMOUNT OF EUR 300,000 AND 4.3 MILLION RESPECTIVELY. THIS
PENALTY WAS IMPOSED FOR BREACH OF THE PROCEDURE LAID DOWN IN ARTICLE 26 (3) OF REGULATION (EU) NO 575/2013 OF THE EUROPEAN
PARLIAMENT BY CLASSIFYING CAPITAL INSTRUMENTS AS COMMON EQUITY TIER 1 INSTRUMENTS DURING THREE (FIVE FOR CASA) CONSECUTIVE
QUARTERLY REPORTING PERIODS AND TWO (THREE FOR CASA) PUBLIC DISCLOSURES IN 2015 AND 2016 WITHOUT THE PRIOR PERMISSION OF THE
COMPETENT AUTHORITY. THE SHORT SUMMARY OF THE DECISION IS FOUND ON THE ECB WEBSITE AT
HTTPS://WWW.BANKINGSUPERVISION.EUROPA.EU/BANKING/SANCTIONS/SHARED/PDF/SSM.180820_PUBLICATION_TEMPLATE.EN.PDF

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):

You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
AMUNDI ASSET MANAGEMENT
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL SERVICES AND MARKETS AUTHORITY, BELGIUM ("FSMA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/07/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
GRIEVANCES RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS
DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN
TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE
GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON
AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT SENT A
CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A
TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
05/07/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
TRANSACTIONAL SETTLEMENT BETWEEN THE BELGIAN REGULATOR AND AMUNDI ASSET MANAGEMENT AND PAYMENT BY AMUNDI ASSET
MANAGEMENT OF A SUM OF 60,000.00 EUROS TOGETHER WITH THE PUBLICATION OF THE SETTLEMENT ON THE FSMA WEBSITE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
GRIEVANCES RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS
DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN
TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE
GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON
AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT SENT A
CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A
TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CREDIT AGRICOLE S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
EUROPEAN COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/19/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AT.39 914
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
CREDIT AGRICOLE S.A.
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
DERIVATIVES - EURO INTEREST RATE DERIVATIVES (EIRD)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DECEMBER 7, 2016, THE EUROPEAN COMMISSION (THE "COMMISSION") ANNOUNCED THAT IT FINED CREDIT AGRICOLE S.A. ("CASA") AND CREDIT
AGRICOLE CORPORATE AND INVESTMENT BANK ("THE BANK"), HSBC, AND JPMORGAN CHASE FOR ANTICOMPETITIVE PRACTICES CONCERNING
BENCHMARK INTEREST RATES. THE COMMISSION CLAIMS THAT THE BANK AND SEVEN OTHER BANKS COLLUDED ON EURO INTEREST RATE DERIVATIVE
PRICING ELEMENTS AND EXCHANGED SENSITIVE INFORMATION FOR THE PURPOSE OF DISTORTING THE NORMAL COURSE OF PRICING COMPONENTS
FOR EURO INTEREST RATE DERIVATIVES, IN BREACH OF EUROPEAN UNION ANTITRUST RULES. THE COMMISSION FOUND THAT THERE WAS A CARTEL IN
PLACE BETWEEN SEPTEMBER 2005 AND MAY 2008 INVOLVING A TOTAL OF SEVEN BANKS (BARCLAYS, HSBC, JPMORGAN CHASE, DEUTSCHE BANK, RBS,
SOCIÉTÉ GÉNÉRALE, AND THE BANK) OVER VARYING TIME PERIODS. THE COMMISSION FOUND THAT THE BANK PARTICIPATED IN THE CARTEL FOR A
DURATION OF 5 MONTHS AND FINED THE BANK 114,654,000 EUROS. THE COMMISSION'S DECISION WAS RELEASED PUBLICLY ON APRIL 9, 2019. THE
BANK HAS APPEALED THE DECISION OF THE COMMISSION BEFORE THE GENERAL COURT OF THE EUROPEAN UNION.

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
EUROPEAN COURT OF JUSTICE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
12/20/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 120,560,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
NONE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE EUROPEAN COMMISSION RELEASED ITS DECISION ON DECEMBER 7, 2016, WITH SUCH DECISION BECOMING PUBLIC ON APRIL 9, 2019. THE
BANK, WHICH HAD PREVIOUSLY ANNOUNCED ITS DECISION TO APPEAL, LODGED ITS APPEAL AND FILED ITS SUBMISSION ON THE MERITS ON
FEBURARY 19, 2017 BEFORE THE GENERAL COURT OF THE EUROPEAN UNION. UPDATE: BY ORDER OF 16 JULY 2020, THE PRESIDENT OF THE EUROPEAN
COURT OF JUSTICE (ECJ) GRANTED CREDIT AGRICOLE (CASA AND CACIB)LEAVE TO INTERVENE IN SUPPORT OF HSBC IN ITS PENDING PROCEEDINGS
BEFORE THE ECJ.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
AMUNDI ASSET MANAGEMENT
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/12/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
PROCÉDURE N°20/10
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
AMUNDI ASSET MANAGEMENT
6.
Principal Product Type:
Futures - Financial
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOLLOWING AN INVESTIGATION CONDUCTED FROM 2017 TO 2019, THE FRENCH FINANCIAL MARKETS AUTHORITY (AUTORITÉ DES MARCHÉS
FINANCIERS [AMF]) NOTIFIED AMUNDI OF GRIEVANCES ON JUNE 12, 2020. THE GRIEVANCES RELATE TO CERTAIN TRANSACTIONS CARRIED OUT
BETWEEN 2014 AND 2015 BY TWO FORMER NON-US EMPLOYEES OF AMUNDI ASSET MANAGEMENT AND A NON-US AMUNDI ASSET MANAGEMENT
AFFILIATE WHO HAVE SINCE BEEN DISMISSED. THE TRANSACTIONS IMPACTED ASSETS MANAGED ON BEHALF OF A NON-US INSTITUTIONAL CLIENT,
WHO WAS COMPENSATED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
08/05/2021
 Exact
 Explanation
If not exact, provide explanation:
FINAL JUDGEMENT
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 37,938,400.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
TWO FORMER AMUNDI EMPLOYEES HAVE BEEN BANNED FROM THE FINANCIAL MARKETS FOR 10 YEARS. THE MONETARY FINE AMOUNT WAS FOR
32 MILLION EURO.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
TWO FORMER AMUNDI EMPLOYEES HAVE BEEN BANNED FROM THE FINANCIAL MARKETS FOR A PERIOD OF 10 YEARS STARTING AUGUST 5, 2021.
TWO AFFILIATES, AMUNDI ASSET MANAGEMENT AND AMUNDI INTERMEDIATION, PAID A FINE OF 25 MILLION EURO AND 7 MILLION EURO
RESPECTIVELY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AFTER A PUBLIC HEARING HELD ON JULY 7, 2021, THE AMF ENFORCEMENT COMMITTEE ON AUGUST 4, 2021 IMPOSED A FINE OF 25 MILLION EURO ON
AMUNDI ASSET MANAGEMENT AND 7 MILLION EURO ON AMUNDI INTERMEDIATION. THE ENFORCEMENT COMMITTEE SANCTIONED TWO FORMER NON-US
EMPLOYEES, EACH BANNED FOR 10 YEARS, AND THE TWO NON-US AMUNDI GROUP COMPANIES FOR PRICE MANIPULATION ON THE EURO STOXX 50
FUTURES (FESX) MARKET AND OTHER BREACHES OF SEVERAL PROFESSIONAL OBLIGATIONS.