Firm profile

Amundi

BOSTON, MACRD 334151Registration Status: ApprovedEffective since January 24, 2025SEC # 801-131764Latest ADV March 31, 2026

Amundi is an SEC registered investment adviser organized as a limited liability company with a primary office location in Boston, MA. Its latest Form ADV filing, dated March 31, 2026, reports $1.1B in regulatory assets under management, 32 employees, 3 offices, and 2 accounts.

Assets Under Management
$1.1B
Employees
32
Offices
3 offices
Total Clients
<5

Associated firm names

3 names listed
  • AMUNDI
  • AMUNDI US INVESTMENT ADVISORS LLC
  • AMUNDI US

Leadership

3 roles identified
CEOFrederic R. Barthelemy
CCOJohn M. Malone
CFOYuri A. Oberle

Advisory services offered

2 types reported
Portfolio management for businesses
Selection of other advisers

Fee models offered

1 types reported
Asset based fees

Offices & Contact

Primary office

BOSTON, Massachusetts, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Massachusetts

BOSTONPrimary office

France

PARIS

Ireland

DUBLIN

3 office records listed · 3 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links
Phone(617)-885-0250
WebsiteNot found
LinkedInNot found

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$1.1Bas of March 31, 2026
Discretionary100.0%
$1.1B
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentCorporations represent 66.7% of total clients.
Top client categories% of clientsClients
1
Corporations
66.7%
2
2
Other Advisers
33.3%
1
Categories with <5 clients
Other investment advisers<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$1.1B
Total Accounts2
10Y AUM Change+$1.1B

Private Funds

Private funds reported by Amundi

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees32
Clients per Employee0:1
10Y Employee Change+5 (+18.5%)

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

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
AMUNDI US INVESTMENT ADVISORS HOLDING LLCDirect owner · Schedule AInterest in AMUNDI US
75%+
AMUNDI ASSET MANAGEMENT S.A.S.Indirect owner · Schedule BInterest in AMUNDI US INVESTMENT ADVISORS HOLDING LLC
75%+
AMUNDI S.A.Indirect owner · Schedule BInterest in AMUNDI ASSET MANAGEMENT S.A.S.
75%+
CRÉDIT AGRICOLE S.A.Indirect owner · Schedule BInterest in AMUNDI S.A.
50% to < 75%
SAS RUE LA BOETIEIndirect owner · Schedule BInterest in CRÉDIT AGRICOLE S.A.
50% to < 75%

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 Amundi.

Reported ownership and control details

Form ADV · Filing date 2026-03-31 · Schedules A and B

8 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1John Michael MaloneCCOIndividualAMUNDI USLess than 5%Code NAYesCCO10/2024Schedule APDF page 33
2FREDERIC ROBERT BARTHELEMYCEOIndividualAMUNDI USLess than 5%Code NAYesCEO09/2024Schedule APDF page 33
3AMUNDI US INVESTMENT ADVISORS HOLDING LLCOWNERDomestic entityAMUNDI US75% or moreCode EYesOWNER09/2024Schedule APDF page 33
4YURI ANTHONY OBERLECFOIndividualAMUNDI USLess than 5%Code NAYesCFO04/2025Schedule APDF page 33
5AMUNDI ASSET MANAGEMENT S.A.S.SHAREHOLDERForeign entityAMUNDI US INVESTMENT ADVISORS HOLDING LLC75% or moreCode EYesSHAREHOLDER09/2024Schedule BPDF page 34
6AMUNDI S.A.SHAREHOLDERForeign entityAMUNDI ASSET MANAGEMENT S.A.S.75% or moreCode EYesSHAREHOLDER11/1978Schedule BPDF page 34
7CRÉDIT AGRICOLE S.A.SHAREHOLDERForeign entityAMUNDI S.A.50% to less than 75%Code DYesSHAREHOLDER11/1978Schedule BPDF page 34
8SAS RUE LA BOETIESHAREHOLDERForeign entityCRÉDIT AGRICOLE S.A.50% to less than 75%Code DYesSHAREHOLDER11/2001Schedule BPDF page 34

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 3/31/2026 2:49:11 PM

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.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
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 actions4 Yes1 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?Yes
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 No
  • 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?No
HCivil judicial actions and proceedings4 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?No
  • 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)?No
Additional DRP filings 7 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 1AMUNDI ASSET MANAGEMENT S.A.S.PDF pages 34–36
Advisory affiliate name — filed text
AMUNDI ASSET MANAGEMENT S.A.S.
Regulator name — filed text
FINANCIAL SERVICES AND MARKETS AUTHORITY, BELGIUM ("FSMA")
Monetary/Fine Amount — filed text
$ 60,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S. SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.
Other filed details

Description of allegations — filed text

GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S. SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.

Sanction detail — filed text

TRANSACTIONAL SETTLEMENT BETWEEN THE BELGIAN REGULATOR AND AMUNDI ASSET MANAGEMENT S.A.S. AND PAYMENT BY AMUNDI ASSET MANAGEMENT S.A.S. OF A SUM OF 60,000 EUROS TOGETHER WITH THE PUBLICATION OF THE SETTLEMENT ON THE FSMA 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:
AMUNDI ASSET MANAGEMENT
S.A.S.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL SERVICES AND MARKETS AUTHORITY, BELGIUM ("FSMA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/07/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS
DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN
TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE
GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON
AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S.
SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO
A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):
05/07/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
TRANSACTIONAL SETTLEMENT BETWEEN THE BELGIAN REGULATOR AND AMUNDI ASSET MANAGEMENT S.A.S. AND PAYMENT BY AMUNDI ASSET
MANAGEMENT S.A.S. OF A SUM OF 60,000 EUROS TOGETHER WITH THE PUBLICATION OF THE SETTLEMENT ON THE FSMA WEBSITE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS
DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN
TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE
GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON
AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S.
SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO
A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.
regulatory · block 2AMUNDI LUXEMBOURG S.A.PDF pages 36–38
Advisory affiliate name — filed text
AMUNDI LUXEMBOURG S.A.
Regulator name — filed text
THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF)
Monetary/Fine Amount — filed text
$ 153,400.00
How was matter resolved — filed text
Decision

Action status / disposition — filed text

THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING / COUNTER-TERRORIST FINANCING.
Other filed details

Description of allegations — filed text

THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING / COUNTER-TERRORIST FINANCING.

Sanction detail — filed text

AMUNDI LUXEMBOURG PAID AN ADMINISTRATIVE FINE OF EUR 153,400.
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:
AMUNDI LUXEMBOURG 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) 
THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/29/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE
CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING /
COUNTER-TERRORIST FINANCING.
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):
07/29/2021
 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: $ 153,400.00
 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: 
AMUNDI LUXEMBOURG PAID AN ADMINISTRATIVE FINE OF EUR 153,400.
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 LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE
CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING /
COUNTER-TERRORIST FINANCING.
regulatory · block 3CRÉDIT AGRICOLE S.A.PDF pages 38–40
Advisory affiliate name — filed text
CRÉDIT AGRICOLE S.A.
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 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) 
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 4PDF pages 40–42
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

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.
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 S.A.
(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 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:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ADMINISTRATIVE PENALTY ON 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.
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 5AMUNDI ASSET MANAGEMENT S.A.S.PDF pages 42–44
Advisory affiliate name — filed text
AMUNDI ASSET MANAGEMENT S.A.S.
Regulator name — filed text
AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
Monetary/Fine Amount — filed text
$ 37,938,400.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

AFTER A PUBLIC HEARING HELD ON JULY 7, 2021, THE AMF ENFORCEMENT COMMITTEE ON AUGUST 4, 2021 IMPOSED A FINE OF 25 MILLION EURO ON AMUNDI ASSET MANAGEMENT S.A.S. AND 7 MILLION EURO ON AMUNDI INTERMEDIATION. THE ENFORCEMENT COMMITTEE SANCTIONED TWO FORMER NON-US EMPLOYEES, EACH BANNED FOR 10 YEARS, AND THE TWO NON-US AMUNDI GROUP COMPANIES FOR PRICE MANIPULATION ON THE EURO STOXX 50 FUTURES (FESX) MARKET AND OTHER BREACHES OF SEVERAL PROFESSIONAL OBLIGATIONS.
Other filed details

Description of allegations — filed text

FOLLOWING AN INVESTIGATION CONDUCTED FROM 2017 TO 2019, THE FRENCH FINANCIAL MARKETS AUTHORITY (AUTORITÉ DES MARCHÉS FINANCIERS [AMF]) NOTIFIED AMUNDI OF GRIEVANCES ON JUNE 12, 2020. THE GRIEVANCES RELATE TO CERTAIN TRANSACTIONS CARRIED OUT BETWEEN 2014 AND 2015 BY TWO FORMER NON-US EMPLOYEES OF AMUNDI ASSET MANAGEMENT S.A.S. AND A NON-US AMUNDI ASSET MANAGEMENT S.A.S. AFFILIATE WHO HAVE SINCE BEEN DISMISSED. THE TRANSACTIONS IMPACTED ASSETS MANAGED ON BEHALF OF A NON-US INSTITUTIONAL CLIENT, WHO WAS COMPENSATED.

Sanction detail — filed text

TWO FORMER AMUNDI EMPLOYEES WERE BANNED FROM THE FINANCIAL MARKETS FOR A PERIOD OF TEN YEARS STARTING AUGUST 5, 2021. TWO AFFILIATES, AMUNDI ASSET MANAGEMENT S.A.S. AND AMUNDI INTERMEDIATION, PAID A FINE OF 25 MILLION EURO AND 7 MILLION RESPECTIVELY.
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:
AMUNDI ASSET MANAGEMENT
S.A.S.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
06/12/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
PROCÉDURE N°20/10
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOLLOWING AN INVESTIGATION CONDUCTED FROM 2017 TO 2019, THE FRENCH FINANCIAL MARKETS AUTHORITY (AUTORITÉ DES MARCHÉS
FINANCIERS [AMF]) NOTIFIED AMUNDI OF GRIEVANCES ON JUNE 12, 2020. THE GRIEVANCES RELATE TO CERTAIN TRANSACTIONS CARRIED OUT
BETWEEN 2014 AND 2015 BY TWO FORMER NON-US EMPLOYEES OF AMUNDI ASSET MANAGEMENT S.A.S. AND A NON-US AMUNDI ASSET MANAGEMENT
S.A.S. AFFILIATE WHO HAVE SINCE BEEN DISMISSED. THE TRANSACTIONS IMPACTED ASSETS MANAGED ON BEHALF OF A NON-US INSTITUTIONAL
CLIENT, WHO WAS COMPENSATED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/05/2021
 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: $ 37,938,400.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction

 Bar
 Suspension
B.
Other Sanctions Ordered:
TWO FORMER AMUNDI EMPLOYEES HAVE BEEN BANNED FROM THE FINANCIAL MARKETS FOR TEN YEARS. THE MONETARY/FINE AMOUNT WAS FOR
32 MILLION EURO.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
TWO FORMER AMUNDI EMPLOYEES WERE BANNED FROM THE FINANCIAL MARKETS FOR A PERIOD OF TEN YEARS STARTING AUGUST 5, 2021. TWO
AFFILIATES, AMUNDI ASSET MANAGEMENT S.A.S. AND AMUNDI INTERMEDIATION, PAID A FINE OF 25 MILLION EURO AND 7 MILLION
RESPECTIVELY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AFTER A PUBLIC HEARING HELD ON JULY 7, 2021, THE AMF ENFORCEMENT COMMITTEE ON AUGUST 4, 2021 IMPOSED A FINE OF 25 MILLION EURO ON
AMUNDI ASSET MANAGEMENT S.A.S. AND 7 MILLION EURO ON AMUNDI INTERMEDIATION. THE ENFORCEMENT COMMITTEE SANCTIONED TWO FORMER
NON-US EMPLOYEES, EACH BANNED FOR 10 YEARS, AND THE TWO NON-US AMUNDI GROUP COMPANIES FOR PRICE MANIPULATION ON THE EURO
STOXX 50 FUTURES (FESX) MARKET AND OTHER BREACHES OF SEVERAL PROFESSIONAL OBLIGATIONS.
regulatory · block 6CRÉDIT AGRICOLE S.A.PDF pages 44–46
Advisory affiliate name — filed text
CRÉDIT AGRICOLE S.A.
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 S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the

circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
EUROPEAN COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/19/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AT.39 914
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
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:
NONE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
NONE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE EUROPEAN COMMISSION RELEASED ITS DECISION ON DECEMBER 7, 2016, WITH SUCH DECISION BECOMING PUBLIC ON APRIL 9, 2019. THE
BANK, WHICH HAD PREVIOUSLY ANNOUNCED ITS DECISION TO APPEAL, LODGED ITS APPEAL AND FILED ITS SUBMISSION ON THE MERITS ON
FEBURARY 19, 2017 BEFORE THE GENERAL COURT OF THE EUROPEAN UNION. UPDATE: BY ORDER OF 16 JULY 2020, THE PRESIDENT OF THE EUROPEAN
COURT OF JUSTICE (ECJ) GRANTED 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 1 more source blocks
regulatory · block 7PDF pages 46–48
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 NOVEMBER 6, 2024: THE GENERAL COURT OF THE EUROPEAN UNION UPHELD THE COMMISSION'S FINDING OF AN INFRINGEMENT AND MAINTAINED THE FINE OF EUR 3,993,000 (US$4,284,565 AS OF NOVEMBER 6, 2024). CACIB AND CASA ELECTED NOT TO APPEAL, AND THE ORDER IS CONSIDERED FINAL. (SEE HTTPS://CURIA.EUROPA.EU/SITE/UPLOAD/DOCS/APPLICATION/PDF/2024-11/CP240186EN.PDF)
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 S.A.
(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:
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
NOVEMBER 6, 2024: THE GENERAL COURT OF THE EUROPEAN UNION UPHELD THE COMMISSION'S FINDING OF AN INFRINGEMENT AND MAINTAINED
THE FINE OF EUR 3,993,000 (US$4,284,565 AS OF NOVEMBER 6, 2024). CACIB AND CASA ELECTED NOT TO APPEAL, AND THE ORDER IS CONSIDERED
FINAL. (SEE HTTPS://CURIA.EUROPA.EU/SITE/UPLOAD/DOCS/APPLICATION/PDF/2024-11/CP240186EN.PDF)

* 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.