Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Petercam Institutional Asset Management
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Petercam Institutional Asset Management.
Reported ownership and control details
Form ADV · Filing date 2026-04-29 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | BANQUE DEGROOF PETERCAM SAOWNERForeign entity | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | 75% or moreCode E | Yes | OWNER10/2013 | Schedule APDF page 21 |
| 2 | PETER DE COENSELDIRECTOR - CHAIRMAN OF THE MANAGEMENT BOARDIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR - CHAIRMAN OF THE MANAGEMENT BOARD10/2021 | Schedule APDF page 21 |
| 3 | LAURENT MARTIN DE MEYEREDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR08/2017 | Schedule APDF page 21 |
| 4 | JEAN-MICHEL LOEHRDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR08/2018 | Schedule APDF page 21 |
| 5 | Yves CEELENDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR05/2019 | Schedule APDF page 21 |
| 6 | Jeroen SionckeDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR01/2020 | Schedule APDF page 21 |
| 7 | SYLVIE HURETDIRECTOR - CHAIRWOMAN OF THE BOARD OF DIRECTORSIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR - CHAIRWOMAN OF THE BOARD OF DIRECTORS06/2021 | Schedule APDF page 21 |
| 8 | Frank van BellingenDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR06/2021 | Schedule APDF page 21 |
| 9 | Sabine CAUDRONDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR08/2022 | Schedule APDF page 21 |
| 10 | Frederiek VAN HOLLEDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR04/2022 | Schedule APDF page 21 |
| 11 | Sam VEREECKEDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR04/2022 | Schedule APDF page 21 |
| 12 | OLIVIER GEORGES CARCYDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR06/2024 | Schedule APDF page 21 |
| 13 | Mathieu François FERRAGUTDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR06/2024 | Schedule APDF page 21 |
| 14 | Ophélie Bénédicte MortierDIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR07/2025 | Schedule APDF page 21 |
| 15 | Anne-Charlotte Yvonne TOESCADIRECTORIndividual | PETERCAM INSTITUTIONAL ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR06/2025 | Schedule APDF page 21 |
| 16 | CA INDOSUEZ S.A.SHAREHOLDERForeign entity | BANQUE DEGROOF PETERCAM SA | 75% or moreCode E | Yes | SHAREHOLDER06/2024 | Schedule BPDF page 22 |
| 17 | CREDIT AGRICOLE CORPORATE AND INVESTMENT BANKSHAREHOLDERForeign entity | CA INDOSUEZ S.A. | 75% or moreCode E | Yes | SHAREHOLDER06/2024 | Schedule BPDF page 22 |
| 18 | CREDIT AGRICOLE SASHAREHOLDERForeign entity | CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK | 75% or moreCode E | Yes | SHAREHOLDER06/2024 | Schedule BPDF page 22 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 4/29/2026 8:21:49 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions3 Yes2 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 Yes
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?Yes
HCivil judicial actions and proceedings2 Yes2 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?Yes
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?Yes
Additional DRP filings 19 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PETERCAM SAPDF pages 22–24
- Advisory affiliate name — filed text
- PETERCAM SA
- Regulator name — filed text
- AMF AUTORITE DES MARCHES FINANCIERS PARIS FRANCE
- Monetary/Fine Amount — filed text
- $ 333,271.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
ADMINISTRATIVE PROSECUTOR ASKS THE PAYMENT OF A FINE EQUAL TO 300.000 EURO/333.271$
Other filed details
Description of allegations — filed text
ALLEGATION OF MARKET ABUSE
Sanction detail — filed text
TOTAL FINE: 410984$ . PAID IN NOVEMBER 2015
Full extracted filing text
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: PETERCAM 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) AMF AUTORITE DES MARCHES FINANCIERS PARIS FRANCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 03/11/2015 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: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ALLEGATION OF MARKET ABUSE 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): 04/16/2015 Exact Explanation If not exact, provide explanation: CASE CLOSED 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 333,271.00 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: TOTAL FINE: 410984$ . PAID IN NOVEMBER 2015 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). ADMINISTRATIVE PROSECUTOR ASKS THE PAYMENT OF A FINE EQUAL TO 300.000 EURO/333.271$
regulatory · block 2BANK DEGROOF PETERCAMPDF pages 24–26
- Advisory affiliate name — filed text
- BANK DEGROOF PETERCAM
- Regulator name — filed text
- FINANCIAL SERVICES AND MARKETS AUTHORITY (FSMA)
- Monetary/Fine Amount — filed text
- $ 110,357.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
INVESTIGATION BY THE FSMA WHICH STARTED IN 2017 AND WHEREBY THE FSMA WAS OF THE VIEW THAT BDP, IN CARRYING OUT ITS LIQUIDITY PROVIDING ACTIVITIES (TRANSACTIONS IN 2016), SENT OUT ''FALSE AND MISLEADING'' SIGNALS THAT AMOUNTED TO ''SPOOFING''. ULTIMATELY THE AUDITOR OF THE FSMA IN ITS CONCLUSION (MAY AND AUGUST 2019) DECIDED TO FURTHER EXTEND THE SCOPE OF THE ALLEGATIONS TO THE BROADER MARKET MANIPULATION. BDP CONTESTED THE ALLEGATIONS BROUGHT FORWARD BY THE AUDITOR OF THE FSMA AND THAT BDP WAS OF THE VIEW THAT IT HAD ACTED WITHIN THE THEN EXISTING REGULATORY FRAMEWORK FOR LIQUIDITY PROVIDING ACTIVITIES. HOWEVER, AFTER ANALYSIS OF THE MATTER AND IN ORDER TO COME TO A SWIFT CLOSE OF THIS MATTER (AND AVOID A PROLONGED ADMINISTRATIVE PROCEDURE WITH THE FSMA, BDP AGREED TO ACCEPT TO ENTER INTO A SETTLEMENT AGREEMENT WITH THE FSMA. THE SETTLEMENT WAS ACCEPTED AND ENTERED INTO BY BDP WITHOUT ADMISSION OF ANY LIABILITY IN ORDER TO HAVE A SWIFT RESOLUTION OF THE MATTER. THE EMPLOYEE IN QUESTION HAS IN THE MEANTIME LEFT THE EMPLOYMENT OF THE BDP. BDP ACCEPTED TO PAY THE SUM OF 100.000 EUR AND THE EMPLOYEE CONCERNED ACCEPTED TO PAY THE SUM OF 25.000 EUR IN THE FRAMEWORK OF THE SETTLEMENT.
Other filed details
Description of allegations — filed text
SPOOFING AND MARKET MANIPULATION IN CARRYING OUT LIQUIDITY PROVIDING ACTIVITIES
Sanction detail — filed text
SETTLEMENT AMOUNT
Full extracted filing text
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: BANK DEGROOF PETERCAM (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 (FSMA) 2. Principal Sanction: Other Other Sanctions: SETTLEMENT AMOUNT 3. Date Initiated (MM/DD/YYYY): 10/11/2017 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: Other Other Product Types: LIQUIDITY PROVIDING FOR SOME EQUITIES LISTED ON EURONEXT BRUSSELS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): SPOOFING AND MARKET MANIPULATION IN CARRYING OUT LIQUIDITY PROVIDING ACTIVITIES 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): 12/13/2019 Exact Explanation If not exact, provide explanation: CLOSED - SETTLEMENT AGREEMENT SIGNED BY THE BANK ON 13 DECEMBER 2019 WITHOUT ADMISSION OF ANY LIABILITY 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 110,357.00 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: SETTLEMENT AMOUNT 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). INVESTIGATION BY THE FSMA WHICH STARTED IN 2017 AND WHEREBY THE FSMA WAS OF THE VIEW THAT BDP, IN CARRYING OUT ITS LIQUIDITY PROVIDING ACTIVITIES (TRANSACTIONS IN 2016), SENT OUT ''FALSE AND MISLEADING'' SIGNALS THAT AMOUNTED TO ''SPOOFING''. ULTIMATELY THE AUDITOR OF THE FSMA IN ITS CONCLUSION (MAY AND AUGUST 2019) DECIDED TO FURTHER EXTEND THE SCOPE OF THE ALLEGATIONS TO THE BROADER MARKET MANIPULATION. BDP CONTESTED THE ALLEGATIONS BROUGHT FORWARD BY THE AUDITOR OF THE FSMA AND THAT BDP WAS OF THE VIEW THAT IT HAD ACTED WITHIN THE THEN EXISTING REGULATORY FRAMEWORK FOR LIQUIDITY PROVIDING ACTIVITIES. HOWEVER, AFTER ANALYSIS OF THE MATTER AND IN ORDER TO COME TO A SWIFT CLOSE OF THIS MATTER (AND AVOID A PROLONGED ADMINISTRATIVE PROCEDURE WITH THE FSMA, BDP AGREED TO ACCEPT TO ENTER INTO A SETTLEMENT AGREEMENT WITH THE FSMA. THE SETTLEMENT WAS ACCEPTED AND ENTERED INTO BY BDP WITHOUT ADMISSION OF ANY LIABILITY IN ORDER TO HAVE A SWIFT RESOLUTION OF THE MATTER. THE EMPLOYEE IN QUESTION HAS IN THE MEANTIME LEFT THE EMPLOYMENT OF THE BDP. BDP ACCEPTED TO PAY THE SUM OF 100.000 EUR AND THE EMPLOYEE CONCERNED ACCEPTED TO PAY THE SUM OF 25.000 EUR IN THE FRAMEWORK OF THE SETTLEMENT.
regulatory · block 3PDF pages 26–28
- Regulator name — filed text
- FINANCIAL SERVICES & MARKETS AUTHORITY (FSMA)
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
ON 14 OCTOBER 2019, THE FSMA REQUESTS DPAM TO PROVIDE WITH FURTHER DETAILS ON AN ADVERTISEMENT PUBLISHED THE SAME DAY. THE ADVERTISEMENT WAS PUBLISHED WITHOUT THEIR PRIOR APPROVAL. A SETTLEMENT AGREEMENT WAS CONCLUDED WITH THE FSMA: PAYMENT OF A SUM OF 50.000 EUR AND THE PUBLICATION OF THE SETTLEMENT ON FSMA'S WEBSITE. PUBLICATION ON THE REGULATOR'S WEBSITE WAS MADE ON 3RD OF JUNE 2020.
Other filed details
Description of allegations — filed text
DISSEMINATION OF AN ADVERTISEMENT WITHOUT PRIOR AUTHORIZATION FROM THE REGULATOR
Sanction detail — filed text
SETTLEMENT AMOUNT AND PUBLICATION ON FSMA'S WEBSITE
Full extracted filing text
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 No Information Filed 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 & MARKETS AUTHORITY (FSMA) 2. Principal Sanction: Other Other Sanctions: SETTLEMENT 3. Date Initiated (MM/DD/YYYY): 10/14/2019 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): N/A 6. Principal Product Type: Other Other Product Types: DISSEMINATION OF AN ADVERTISEMENT WITHOUT PRIOR AUTHORIZATION FROM THE REGULATOR 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): DISSEMINATION OF AN ADVERTISEMENT WITHOUT PRIOR AUTHORIZATION FROM THE REGULATOR 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): 06/03/2020 Exact Explanation If not exact, provide explanation: CASE CLOSED - SETTLEMENT AGREEMENT WITH FSMA AND PUBLICATION ON REGULATOR'S WEBSITE 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: SETTLEMENT AMOUNT AND PUBLICATION ON FSMA'S WEBSITE 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: SETTLEMENT AMOUNT AND PUBLICATION ON FSMA'S 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). ON 14 OCTOBER 2019, THE FSMA REQUESTS DPAM TO PROVIDE WITH FURTHER DETAILS ON AN ADVERTISEMENT PUBLISHED THE SAME DAY. THE ADVERTISEMENT WAS PUBLISHED WITHOUT THEIR PRIOR APPROVAL. A SETTLEMENT AGREEMENT WAS CONCLUDED WITH THE FSMA: PAYMENT OF A SUM OF 50.000 EUR AND THE PUBLICATION OF THE SETTLEMENT ON FSMA'S WEBSITE. PUBLICATION ON THE REGULATOR'S WEBSITE WAS MADE ON 3RD OF JUNE 2020.
regulatory · block 4BANK DEGROOF PETERCAMPDF pages 28–29
- Advisory affiliate name — filed text
- BANK DEGROOF PETERCAM
- Regulator name — filed text
- FINANCIAL SERVICES AND MARKETS AUTHORITY (FSMA)
- Monetary/Fine Amount — filed text
- $ 412,820.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
AUDIT OF THE FSMA NOTIFIED AN ALLEGED INFRINGEMENT OF THE MARKET ABUSE REGULATION ON THE MISSING NOTIFICATION OF THE "SUSPICIOUS" TRANSACTIONS AND ORDERS REPORT" FOR THE PERIOD 1ST JANUARY 2015 TO 25TH OF JUNE 2015. ON 2ND JULY 2020: FINAL DECISION ON AN ADMINISTRATIVE FINES EQUAL TO 350000 EUR AND NO PUBLICATION ON THE REGULATOR'S WEBSITE.
Other filed details
Description of allegations — filed text
FAILURE TO NOTIFY SUSPICIOUS TRANSACTIONS FOR PERIOD 01/01/2015 TO 06/25/2015 INFRINGEMENT OF THE REGULATION RELATED TO THE MARKET ABUSE.
Sanction detail — filed text
ADMINISTRATIVE FINES EQUAL TO 350000 EUR AND NO PUBLICATION ON THE REGULATOR'S WEBSITE.
Full extracted filing text
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: BANK DEGROOF PETERCAM (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 (FSMA) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/18/2019 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: Other Other Product Types: MISSING NOTIFICATION OF SUSPICIOUS TRANSACTIONS AND ORDERS REPORT 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FAILURE TO NOTIFY SUSPICIOUS TRANSACTIONS FOR PERIOD 01/01/2015 TO 06/25/2015 INFRINGEMENT OF THE REGULATION RELATED TO THE MARKET ABUSE. 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): 07/02/2020 Exact Explanation If not exact, provide explanation: CASE CLOSED ADMINISTRATIVE FINES NO PUBLICATION 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 412,820.00 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: ADMINISTRATIVE FINES EQUAL TO 350000 EUR AND NO PUBLICATION ON THE REGULATOR'S 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). AUDIT OF THE FSMA NOTIFIED AN ALLEGED INFRINGEMENT OF THE MARKET ABUSE REGULATION ON THE MISSING NOTIFICATION OF THE "SUSPICIOUS" TRANSACTIONS AND ORDERS REPORT" FOR THE PERIOD 1ST JANUARY 2015 TO 25TH OF JUNE 2015. ON 2ND JULY 2020: FINAL DECISION ON AN ADMINISTRATIVE FINES EQUAL TO 350000 EUR AND NO PUBLICATION ON THE REGULATOR'S WEBSITE.
regulatory · block 5BANK DEGROOF PETERCAMPDF pages 29–31
- Advisory affiliate name — filed text
- BANK DEGROOF PETERCAM
- Regulator name — filed text
- FINANCIAL SERVICES AND MARKETS AUTHORITY (FSMA)
- Monetary/Fine Amount — filed text
- $ 943,590.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
BREACH OF CERTAIN MIFID RULES NOTIFIED BY THE FSMA. SETTLEMENT AGREEMNT WITH THE FSMA EQUAL TO EUR 800000 AND PUBLICATION ON THE REGULATOR'S WEBSITE ON 28/07/2020
Other filed details
Description of allegations — filed text
ALLEGED BREACH OF CERTAIN MIFID RULES GAPS IN THE CONSIDERATION OF CUSTOMER KNOWLEDGE FOR THE ASSESSMENT OF SUITABILITY TEST, CONSIDERATION OF CERTAIN OUTDATED PROFILES
Sanction detail — filed text
SETTLEMENT AGREEMNT WITH THE FSMA EQUAL TO EUR 800000
Full extracted filing text
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: BANK DEGROOF PETERCAM (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 (FSMA) 2. Principal Sanction: Other Other Sanctions: SETTLEMENT 3. Date Initiated (MM/DD/YYYY): 06/25/2019 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: Other Other Product Types: ALLEGED BREACH OF CERTAIN RULES OF CONDUCT MIFID I & MIFID II 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ALLEGED BREACH OF CERTAIN MIFID RULES GAPS IN THE CONSIDERATION OF CUSTOMER KNOWLEDGE FOR THE ASSESSMENT OF SUITABILITY TEST, CONSIDERATION OF CERTAIN OUTDATED PROFILES 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): 07/17/2020 Exact Explanation If not exact, provide explanation: CLOSED - TRANSACTIONAL SETTLEMENT 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 943,590.00 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: SETTLEMENT AGREEMNT WITH THE FSMA EQUAL TO EUR 800000 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). BREACH OF CERTAIN MIFID RULES NOTIFIED BY THE FSMA. SETTLEMENT AGREEMNT WITH THE FSMA EQUAL TO EUR 800000 AND PUBLICATION ON THE REGULATOR'S WEBSITE ON 28/07/2020
regulatory · block 6CRÉDIT AGRICOLE SAPDF pages 31–33
- Advisory affiliate name — filed text
- CRÉDIT AGRICOLE SA
- Regulator name — filed text
- EUROPEAN COMMISSION
- Monetary/Fine Amount — filed text
- $ 120,560,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
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 CRÉDIT AGRICOLE (CASA AND CACIB) LEAVE TO INTERVENE IN SUPPORT OF HSBC IN ITS PENDING PROCEEDINGS BEFORE THE ECJ. UPDATE AS OF JULY 2, 2024: ON DECEMBER 20, 2023,THE GENERAL COURT OF THE EUROPEAN UNION ISSUED A JUDGEMENT. THE GENERAL COURT REDUCED THE AMOUNT OF CACIB AND CASA'S FINE TO EUR 110M ANDHAD UPHELD MOST OF THE COMMISSION'S DECISION OF DECEMBER 2016. ON MARCH 8, 2024, CASA AND CACIB HAVE APPEALED THE RULING BEFORE THE ECJ.
Other filed details
Description of allegations — filed text
ON DECEMBER 7, 2016, THE EUROPEAN COMMISSION (THE "COMMISSION") ANNOUNCED THAT IT FINED CRÉDIT AGRICOLE S.A. ("CASA") AND CRÉDIT 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.
Sanction detail — filed text
NONE
Full extracted filing text
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:
CRÉDIT 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)
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):
CRÉDIT 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 CRÉDIT AGRICOLE S.A. ("CASA") AND CRÉDIT
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:
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 CRÉDIT AGRICOLE (CASA AND CACIB) LEAVE TO INTERVENE IN SUPPORT OF HSBC IN ITS PENDING PROCEEDINGS
BEFORE THE ECJ. UPDATE AS OF JULY 2, 2024: ON DECEMBER 20, 2023,THE GENERAL COURT OF THE EUROPEAN UNION ISSUED A JUDGEMENT. THE
GENERAL COURT REDUCED THE AMOUNT OF CACIB AND CASA'S FINE TO EUR 110M ANDHAD UPHELD MOST OF THE COMMISSION'S DECISION OF
DECEMBER 2016. ON MARCH 8, 2024, CASA AND CACIB HAVE APPEALED THE RULING BEFORE THE ECJ.Show 13 more source blocks
regulatory · block 7PDF pages 33–35
- Regulator name — filed text
- EUROPEAN CENTRAL BANK
- Monetary/Fine Amount — filed text
- $ 4,600,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
THE EUROPEAN CENTRAL BANK (ECB) DECIDED ON JULY 16, 2018 TO IMPOSE AN ADMINISTRATIVE PENALTY ON CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CRÉDIT AGRICOLE S.A. (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_1_PUBLICATION_TEMPLATE.EN.PDF
Other filed details
Description of allegations — filed text
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.
Sanction detail — filed text
N/A
Full extracted filing text
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: CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (For individuals, Last, First, Middle) CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: CRÉDIT 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) 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): CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK & CRÉDIT AGRICOLE S.A. 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: ADMINISTRATIVE PENALTY ON CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CRÉDIT AGRCICOLE S.A. (CASA), AMOUNTING TO EUR 300,000 AND 4.3 MILLION RESPECTIVELY. 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 CENTRAL BANK (ECB) DECIDED ON JULY 16, 2018 TO IMPOSE AN ADMINISTRATIVE PENALTY ON CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CRÉDIT AGRICOLE S.A. (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_1_PUBLICATION_TEMPLATE.EN.PDF
regulatory · block 8PDF pages 35–38
- Regulator name — filed text
- EUROPEAN COMMISSION
- Monetary/Fine Amount — filed text
- $ 4,821,967.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
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: CASAAND CACIB FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND PENALTY IMPOSED, ON JULY7, 2021. UPDATE AS OF JULY 2,2024: THERE IS NO UPDATED RULING ON THE CASE. DECISION FROM THE EUROPEAN COMMISSION IS EXPECTED ON NOVEMBER 2024.
Other filed details
Description of allegations — filed text
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.
Sanction detail — filed text
N/A
Full extracted filing text
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:
CRÉDIT AGRICOLE SA
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
CRÉDIT 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):
CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) & CRÉDIT 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:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 4,821,967.00
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: CASAAND CACIB
FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND PENALTY IMPOSED, ON JULY7, 2021. UPDATE AS OF JULY
2,2024: THERE IS NO UPDATED RULING ON THE CASE. DECISION FROM THE EUROPEAN COMMISSION IS EXPECTED ON NOVEMBER 2024.regulatory · block 9CRÉDIT AGRICOLE SAPDF pages 38–40
- Advisory affiliate name — filed text
- CRÉDIT AGRICOLE SA
- Regulator name — filed text
- BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
- Monetary/Fine Amount — filed text
- $ 787,300,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
CIVIL ORDER AND SANCTIONS OF $787.3 MILLION
Other filed details
Description of allegations — filed text
CRÉDIT AGRICOLE S.A. (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.
Sanction detail — filed text
NO ADDITIONAL DETAILS ARE AVAILABLE
Full extracted filing text
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: CRÉDIT 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: Other Other Product Types: BANKING PRODUCTS (OTHER THAN CD(S)) 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): CRÉDIT AGRICOLE S.A. (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
regulatory · block 10CA INDOSUEZ SWITZERLAND S.APDF pages 40–41
- Advisory affiliate name — filed text
- CA INDOSUEZ SWITZERLAND S.A
- Regulator name — filed text
- (OFAC) U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL
- Monetary/Fine Amount — filed text
- $ 720,258.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
POTENTIAL CIVIL LIABILITY FOR APPARENT VIOLATIONS OF THE CUBA, UKRAINE-RELATED, IRAN, SUDAN, AND SYRIA SANCTIONS PROGRAMS. AS A RESULT OF DEFICIENCIES RELATED TO CAIS'S SANCTIONS COMPLIANCE PRACTICES, FOR APPROXIMATELY THREE YEARS CAIS OPERATED U.S. DOLLAR (USD) BANKING AND SECURITIES ACCOUNTS ON BEHALF OF 17 INDIVIDUAL CUSTOMERS LOCATED IN SANCTIONED JURISDICTIONS AND CONDUCTED USD BUSINESS ON BEHALF OF THESE CUSTOMERS THROUGH THE U.S. FINANCIAL SYSTEM, INCLUDING THROUGH U.S. CORRESPONDENT BANKS AND U.S. REGISTERED BROKERS OR DEALERS IN SECURITIES.
Other filed details
Description of allegations — filed text
CAIS COLLECTS ACCOUNT HOLDERS' KYC DATA, INCLUDING ADDRESS INFORMATION THAT INDICATES THE LOCATION OF THE ACCOUNT HOLDER(S). DESPITE HAVING SUCH INFORMATION, FROM APRIL 2013 TO APRIL 2016, CAIS ALLOWED CUSTOMERS LOCATED IN THESE SANCTIONED JURISDICTIONS TO PURCHASE SECURITIES ISSUED BY U.S. COMPANIES THROUGH U.S. BROKER-DEALERS AND OTHER U.S. MARKET PARTICIPANTS, IN TOTAL 240 TRANSACTIONS TOTALING $2,050,780,IN APPARENT VIOLATION OF U.S. SANCTIONS. CAIS ALSO ALLOWED THESE CUSTOMERS TO ENGAGE IN 33 COMMERCIAL TRANSACTIONS TOTALING APPROXIMATELY $1,025,400 THROUGH U.S. BANKING CORRESPONDENTS IN APPARENT VIOLATION OF U.S. SANCTIONS.
Sanction detail — filed text
SETTLED AMOUNT
Full extracted filing text
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: CA INDOSUEZ SWITZERLAND 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) (OFAC) U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL 2. Principal Sanction: Other Other Sanctions: MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 01/02/2018 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: Other Other Product Types: SECURITIES ISSUED BY U.S COMPANIES VARIOUS COMMERCIAL TRANSACTIONS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): CAIS COLLECTS ACCOUNT HOLDERS' KYC DATA, INCLUDING ADDRESS INFORMATION THAT INDICATES THE LOCATION OF THE ACCOUNT HOLDER(S). DESPITE HAVING SUCH INFORMATION, FROM APRIL 2013 TO APRIL 2016, CAIS ALLOWED CUSTOMERS LOCATED IN THESE SANCTIONED JURISDICTIONS TO PURCHASE SECURITIES ISSUED BY U.S. COMPANIES THROUGH U.S. BROKER-DEALERS AND OTHER U.S. MARKET PARTICIPANTS, IN TOTAL 240 TRANSACTIONS TOTALING $2,050,780,IN APPARENT VIOLATION OF U.S. SANCTIONS. CAIS ALSO ALLOWED THESE CUSTOMERS TO ENGAGE IN 33 COMMERCIAL TRANSACTIONS TOTALING APPROXIMATELY $1,025,400 THROUGH U.S. BANKING CORRESPONDENTS IN APPARENT VIOLATION OF U.S. SANCTIONS. 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): 09/26/2022 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: $ 720,258.00 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: SETTLED AMOUNT 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). POTENTIAL CIVIL LIABILITY FOR APPARENT VIOLATIONS OF THE CUBA, UKRAINE-RELATED, IRAN, SUDAN, AND SYRIA SANCTIONS PROGRAMS. AS A RESULT OF DEFICIENCIES RELATED TO CAIS'S SANCTIONS COMPLIANCE PRACTICES, FOR APPROXIMATELY THREE YEARS CAIS OPERATED U.S. DOLLAR (USD) BANKING AND SECURITIES ACCOUNTS ON BEHALF OF 17 INDIVIDUAL CUSTOMERS LOCATED IN SANCTIONED JURISDICTIONS AND CONDUCTED USD BUSINESS ON BEHALF OF THESE CUSTOMERS THROUGH THE U.S. FINANCIAL SYSTEM, INCLUDING THROUGH U.S. CORRESPONDENT BANKS AND U.S. REGISTERED BROKERS OR DEALERS IN SECURITIES.
regulatory · block 11CFM INDOSUEZ WEALTHPDF pages 41–43
- Advisory affiliate name — filed text
- CFM INDOSUEZ WEALTH
- Regulator name — filed text
- (OFAC) U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL
- Monetary/Fine Amount — filed text
- $ 401,039.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
POTENTIAL CIVIL LIABILITY FOR APPARENT VIOLATIONS OF SANCTIONS AGAINST CUBA, IRAN, AND SYRIA. CFM OPERATED U.S. DOLLAR (USD) BANKING AND SECURITIES ACCOUNTS ON BEHALF OF 11 INDIVIDUAL CUSTOMERS LOCATED IN SANCTIONED JURISDICTIONS AND CONDUCTED USD BUSINESS ON BEHALF OF THESE CUSTOMERS THROUGH THE U.S. FINANCIAL SYSTEM, INCLUDING THROUGH U.S. CORRESPONDENT BANKS AND U.S. REGISTERED BROKERS OR DEALERS IN SECURITIES.
Other filed details
Description of allegations — filed text
CFM COLLECTED ACCOUNT HOLDERS' KYC DATA, INCLUDING ADDRESS INFORMATION THAT INDICATES THE LOCATION OF THE ACCOUNT HOLDER(S). DESPITE HAVING SUCH INFORMATION, FROM DECEMBER 2011 UNTIL JULY 2016, CFM ALLOWED CUSTOMERS LOCATED IN THESE SANCTIONED JURISDICTIONS TO PURCHASE SECURITIES ISSUED BY U.S. COMPANIES THROUGH U.S. BROKER-DEALERS AND OTHER U.S. MARKET PARTICIPANTS, IN TOTAL 410 TRANSACTIONS TOTALING $966,491
Sanction detail — filed text
SETTLED AMOUNT
Full extracted filing text
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: CFM INDOSUEZ WEALTH (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) (OFAC) U.S. DEPARTMENT OF THE TREASURY'S OFFICE OF FOREIGN ASSETS CONTROL 2. Principal Sanction: Other Other Sanctions: MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 01/02/2018 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): CFM INDOSUEZ WEALTH 6. Principal Product Type: Other Other Product Types: SECURITIES ISSUED BY U.S COMPANIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): CFM COLLECTED ACCOUNT HOLDERS' KYC DATA, INCLUDING ADDRESS INFORMATION THAT INDICATES THE LOCATION OF THE ACCOUNT HOLDER(S). DESPITE HAVING SUCH INFORMATION, FROM DECEMBER 2011 UNTIL JULY 2016, CFM ALLOWED CUSTOMERS LOCATED IN THESE SANCTIONED JURISDICTIONS TO PURCHASE SECURITIES ISSUED BY U.S. COMPANIES THROUGH U.S. BROKER-DEALERS AND OTHER U.S. MARKET PARTICIPANTS, IN TOTAL 410 TRANSACTIONS TOTALING $966,491 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): 09/26/2022 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: $ 401,039.00 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: SETTLED AMOUNT 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). POTENTIAL CIVIL LIABILITY FOR APPARENT VIOLATIONS OF SANCTIONS AGAINST CUBA, IRAN, AND SYRIA. CFM OPERATED U.S. DOLLAR (USD) BANKING AND SECURITIES ACCOUNTS ON BEHALF OF 11 INDIVIDUAL CUSTOMERS LOCATED IN SANCTIONED JURISDICTIONS AND CONDUCTED USD BUSINESS ON BEHALF OF THESE CUSTOMERS THROUGH THE U.S. FINANCIAL SYSTEM, INCLUDING THROUGH U.S. CORRESPONDENT BANKS AND U.S. REGISTERED BROKERS OR DEALERS IN SECURITIES.
civil judicial · block 1PDF pages 43–45
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 01/10/2012 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Investment Contract(s) Other Product Types: 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): CIVIL COURT OF BRUSSELS (BELGIUM) 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGATIONS ARE RELATED TO THE QUESTION WHETHER OUR FIRM WAS IN COMPLIANCE WITH THE INVESTMENT CONTRACT. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 01/10/2012 Exact Explanation If not exact, provide explanation: CASE CLOSED If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Settled 12. Resolution Date (MM/DD/YYYY): 06/30/2013 Exact Explanation If not exact, provide explanation: CASE CLOSED 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: NONE C. 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 SANCTIONS 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). NO SANCTIONS
civil judicial · block 2PDF pages 45–47
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 10/19/2010 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Debt - Corporate Other Product Types: INVESTMENT CONTRACT(S) MUTUAL FUND(S) 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): CIVIL COURT OF BRUSSELS (BELGIUM) 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGATIONS ARE RELATED TO THE ABSENCE OF DIVERSIFICATION OF THE PORTFOLIO UNDER MANAGEMENT AND THE IMPORTANT AMOUNT OF SUBORDINATED AND PERPETUAL DEBT SECURITIES. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Settled 12. Resolution Date (MM/DD/YYYY): 07/06/2021 Exact Explanation If not exact, provide explanation: CASE CLOSED 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: NONE C. 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 SANCTIONS 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). NO SANCTIONS
civil judicial · block 3PDF pages 47–49
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 07/28/2011 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Other Other Product Types: PRIVATE EQUITY FUND 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): COURT OF BRUSSELS (BELGIUM) 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGATIONS ARE RELATED TO THE QUESTION WHETHER PETERCAM WAS MANAGING THE UNITHOLDERS PROPERLY. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 07/28/2011 Exact Explanation If not exact, provide explanation: CASE CLOSED If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Settled 12. Resolution Date (MM/DD/YYYY): 11/30/2013 Exact Explanation If not exact, provide explanation: CASE CLOSED 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: NONE C. 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 SANCTIONS 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). NO SANCTIONS
civil judicial · block 4PDF pages 49–51
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 09/28/2012 Exact Explanation If not exact, provide explanation: COURT OF BRUSSELS 4. Principal Product Type: Debt - Corporate Other Product Types: INVESTMENT CONTRACT(S) MUTUAL FUND(S) 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): COURT OF BRUSSELS 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGATIONS ARE RELATED TO THE QUESTION WHETHER PETERCAM HAS INVESTED IN COMPLIANCE WITH THE INVESTMENT CONTRACT 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 09/28/2012 Exact Explanation If not exact, provide explanation: CASE CLOSED If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Settled 12. Resolution Date (MM/DD/YYYY): 01/31/2014 Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: NONE C. 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 SANCTIONS 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). NO SANCTIONS
civil judicial · block 5PDF pages 51–53
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 05/01/2011 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Investment Contract(s) Other Product Types: MUTUAL FUND(S) 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): COURT OF APPEAL OF BRUSSELS (BELGIUM) 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGATIONS ARE RELATED TO THE QUESTION WHETHER PETERCAM HAS MADE THE APPROPRIATE INVESTMENTS IN COMPLIANCE WITH THE INVESTMENT CONTRACT 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): COURT OF APPEAL BRUSSELS (BELGIUM) 10. If pending, date notice/process was served (MM/DD/YYYY): 12/04/2012 Exact Explanation If not exact, provide explanation: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Judgment Rendered 12. Resolution Date (MM/DD/YYYY): 06/30/2022 Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: CLAIM OF THE PRIVATE PLAINTIFFS (FINANCIAL COMPENSATION) WAS REJECTED IN FIRST INSTANCE. THE PROCEDURE IS NOW IN APPEAL. C. 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: FINANCIAL COMPENSATION. SEE ABOVE. 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). JUDGMENT RENDERED ON JUNE 30, 2022 IN FAVOR OF OUR MOTHER COMPANY: THE COURT DECLARED THE COUNTERPARTY CLAIMS UNFOUNDED. THE PARTIES DECIDED NOT TO APPEAL TO THE SUPREME COURT AND SIGNED THE ACE OF ACQUIESCENCE IN OCTOBER 2022. CASE CLOSED.
civil judicial · block 6PDF pages 53–54
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFFS 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 09/21/2015 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Other Other Product Types: PRIVATE EQUITY FUND 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): TRIBUNAL OF BRUSSELS (BELGIUM) AND CRIMINAL INSTRUCTION 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): - ALLEGED BREACH TO THE PUBLIC OFFERING LEGISLATION - MISLEADING INFORMATION OF THE MEMORANDUM OF INFORMATION - EQUAL TREATMENT OF THE SHAREHOLDERS 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 09/21/2015 Exact Explanation If not exact, provide explanation: PENDING (CRIMINAL CASE CLOSED) If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: 12. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: C. 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: 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). ALLEGATION OF MISLEADING INFORMATION
civil judicial · block 7PDF pages 54–56
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: BANK DEGROOF PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 04/09/2009 Exact Explanation If not exact, provide explanation: FILED IN 2009 BEFORE THE MERGER BETWEEN DEGROOF AND PETERCAM 4. Principal Product Type: Mutual Fund(s) Other Product Types: 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): TRIBUNAL OF BRUSSELS - BELGIUM 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): INVESTMENT NOT COMPLIANT TO THE RISK PROFILE OF THE CLIENT 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): ACTION APPEALED TO THE COURT OF APPEAL OF BRUSSELS COURT OF APPEAL DECISION OF 09/06/2019. ACTION OF PLAINTIFF REJECTED. RECOURSE TO THE SUPREME COURT INTRODUCED BY THE DISMISSED PARTY ON 19 NOVEMBER 2020 SUPREME COURT REJECTED RECOUSE OF DISSMISSED PARTY - CASE CLOSED 10. If pending, date notice/process was served (MM/DD/YYYY): 09/10/2021 Exact Explanation If not exact, provide explanation: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Dismissed 12. Resolution Date (MM/DD/YYYY): 09/10/2021 Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: C. 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: FINANCIAL COMPENSATION DISSMISSED 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). REQUEST OF THE PLAINTIFF TO PAY MONETARY DAMAGES - DISMISSED BY JUDGEMENT ON 09/06/2019 RECOURSE TO THE SUPREME COURT REQUESTED BY DISMISSED PARTY ON 19TH NOVEMBER 2020 SUPREME COURT REJECTED RECOUSE OF DISSMISSED PARTY - CASE CLOSED FINAL DECISION OF THE SUPREME COURT HAS DISSMISSED THE RECOURSE OF THE DISSMISSED PARTY
civil judicial · block 8PDF pages 56–58
Full extracted filing text
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: PETERCAM (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.H. (1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFFS 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 09/21/2015 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Other Other Product Types: PRIVATE EQUITY FUND 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): TRIBUNAL OF BRUSSELS (BELGIUM) 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ALLEGED BREACH TO THE PUBLIC OFFERING LEGISLATION - MISLEADING INFORMATION OF THE MEMORANDUM OF INFORMATION - EQUAL TREATMENT OF THE SHAREHOLDERS 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 09/21/2015 Exact Explanation If not exact, provide explanation: PENDING If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: 12. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: C. 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: 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). REQUEST FROM THE PLAINTIFFS TO PRODUCE COMPLEMENTARY AND ADDITIONAL INFORMATION
* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.