Loading
Finance
12 min read
Areas of Expertise :
Finance, Asset Management, Portfolio Management, Risk Management, Forensic Accounting
Published Date:
Last Modified Date:
Jurisdiction:
United Kingdom Administrative
H2O AM LLP came under regulatory scrutiny after several of its investment funds built substantial exposure to companies controlled by or introduced through financier Lars Windhorst. Between 2015 and 2019, H2O invested in 24 such entities through private debt, equity interests, and other securities. Many of these assets were harder to sell than the liquid securities normally held in open-ended investment funds. The Financial Conduct Authority later found that H2O had not carried out adequate due diligence on many of the investments and had weaknesses in its valuation procedures, risk controls, record keeping, and management of conflicts of interest. By August 2020, the assets later transferred into segregated side-pocket funds were valued at about €1.643 billion.
The events led to separate regulatory and court proceedings in the United Kingdom and France. In August 2020, the Autorité des marchés financiers requested the suspension of subscriptions and redemptions in three H2O UCITS funds, and H2O extended the suspension to five additional funds. The AMF later imposed financial sanctions on H2O and two former executives. In 2024, the FCA publicly censured H2O after finding breaches of three regulatory principles under a settlement in which the H2O Group had voluntarily secured €250 million for affected side-pocket investors. Later proceedings included a rejected UK judicial-review application, French administrative appeals, regulatory action against former H2O deputy CEO Jean-Noel Alba, an AMF sanction against fund custodian CACEIS Bank, and civil claims brought by thousands of investors in France.
H2O invested fund assets in 24 companies controlled by or introduced through Lars Windhorst. The investments included private placement debt and equity interests in early-stage or turnaround businesses, making many of the holdings less liquid than securities traded on public markets. The FCA found that half of the 24 investments had no record of due-diligence analysis when they were made. Ten had an Investment Decision Note, and seven of those also had a longer Investment Summary, although six of the seven summaries contained no risk analysis or evidence of independent valuation or financial analysis. Only two investments had any record of basic financial analysis.
Public reporting about H2O's exposure to Windhorst-linked investments appeared in June 2019 and was followed by substantial investor withdrawals. By mid-July, approximately €8 billion had been redeemed from the roughly €34 billion H2O managed at the start of June. The FCA sent information requests to H2O in August, October, and November as it examined how the firm selected, reviewed, and monitored the investments. The regulator later found that H2O supplied false or misleading information, created records for meetings that had not taken place, and provided investment research prepared after earlier transactions while presenting that research as work completed at the time.
On August 28, 2020, the AMF requested the suspension of subscriptions and redemptions in H2O Allegro, H2O MultiBonds, and H2O MultiStrategies because of their exposure to investments with valuation uncertainty. H2O then extended the suspension to five additional funds: H2O Adagio, H2O Moderato, H2O MultiEquities, H2O Vivace, and H2O Deep Value. During September and October, Windhorst-linked investments held by seven affected French UCITS funds were placed into segregated side-pocket funds closed to subscriptions and redemptions, while their other assets were transferred into open funds. The FCA later recorded the estimated value of the assets placed into the side pockets at approximately €1.643 billion as of August 2020.
The AMF Enforcement Committee fined H2O AM LLP €75 million and issued a reprimand over its management of seven French UCITS funds. Former CEO Bruno Crastes received a €15 million fine and a five-year ban from serving in the management roles covered by the AMF decision. Former chief investment officer Vincent Chailley received a €3 million fine and a reprimand. The proceedings addressed direct acquisitions of Tennor Group securities and buy-and-sell-back transactions, with findings concerning liquidity, valuation, investment limits, fund rules, and counterparty exposure.
Thousands of H2O fundholders brought civil claims in France against parties connected with the management, custody, auditing, and distribution of the affected funds. Defendants named in the litigation included H2O entities, CACEIS Bank, Natixis Investment Managers, and KPMG Audit, with other parties later added to the proceedings. The claimants included direct fundholders as well as some investors whose life insurance contracts contained units linked to the affected H2O funds. The civil action seeks compensation for alleged losses associated with assets that were separated into side-pocket funds in 2020.
On August 7, 2024, the FCA announced the outcome of its investigation and published details of a Final Notice dated August 2, 2024. The FCA imposed a public censure on H2O AM LLP after finding breaches of Principle 2, concerning skill, care, and diligence; Principle 3, concerning management and control; and Principle 11, concerning relations with regulators. Under the settlement terms, the H2O Group had voluntarily secured €250 million for current unitholders in the side-pocketed funds and formally waived rights to fees and investments totaling €320 million for their benefit. H2O AM LLP also agreed to apply voluntarily to cancel its UK regulatory permissions by December 31, 2024.
The FCA's findings also addressed H2O's controls over gifts, hospitality, and conflicts of interest. It found that H2O failed to record gifts and hospitality provided by Windhorst to H2O staff and their family members either at all or in sufficient detail. The FCA reported more than 50 instances in which hospitality had been received by H2O employees but had not been properly declared. Examples included meals, sporting events, private-jet travel, and use of a superyacht.
Collectif Porteurs H2O sought permission to pursue judicial review of the FCA's 2024 Final Notice. The investor group challenged the regulatory resolution associated with the €250 million arrangement for side-pocket unitholders. In February 2025, the High Court refused permission for the judicial-review claim to proceed. The FCA's Final Notice therefore remained in force without a full judicial-review hearing.
H2O AM LLP, Bruno Crastes, and Vincent Chailley challenged the AMF Enforcement Committee's 2022 sanctions before France's Conseil d'État. The court dismissed their applications on June 13, 2025. The €75 million sanction against H2O, the €15 million sanction and management ban imposed on Crastes, and the €3 million sanction against Chailley remained in place. The court also ordered payments toward the AMF's legal costs.
The FCA fined former H2O deputy CEO Jean-Noel Alba £1,049,500 and barred him from working in the UK financial-services industry. Alba had served as one of H2O's main contacts during the FCA investigation. The regulator found that he directed junior employees to create records for meetings that had not formally occurred and supplied investment research prepared after certain investments while presenting it as earlier work. The FCA later confirmed that Alba was the individual previously identified as "Senior Manager A" in the H2O Final Notice.
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning concerning its duties as custodian for seven French funds managed by H2O. The regulator identified deficiencies in controls involving investment ratios, valuations of unlisted securities, and compliance with restrictions contained in fund documents and financial regulations. CACEIS Bank filed an appeal with the Conseil d'État on February 26, 2026. The appeal concerns the custodian's regulatory responsibilities and is separate from the sanctions previously imposed on H2O and its former executives.
The civil action brought by H2O fundholders remained active in 2026. On April 17, the First President of the Paris Court of Appeal ordered the proceedings transferred to the Bobigny Commercial Court after grounds for recusal were identified concerning several judges involved in the case. Corporate disclosures from parties to the litigation continued to report thousands of claimants seeking compensation from H2O and other defendants. The transfer concerned the investor damages proceedings and did not reopen the completed FCA enforcement action against H2O.
In June 2026, H2O announced that it had completed the disposal of the remaining assets held in its side-pocket funds. The firm said the affected funds would be liquidated in July and that a final repayment of €135.7 million would follow earlier distributions made in January 2023 and March 2024. The repayment was scheduled to occur automatically for eligible unitholders. Liquidation of the remaining side-pocket assets did not end the separate civil claims being pursued by investors in France.
Court:
Financial Conduct Authority
Case Name:
H2O AM LLP
Asset Valuation
Portfolio Valuation
Mutual funds
Financial Fraud
Internal Audit
Risk Assessment
Corporate Finance
Investment Fraud
H2O AM LLP came under regulatory scrutiny after several of its investment funds built substantial exposure to companies controlled by or introduced through financier Lars Windhorst. Between 2015 and 2019, H2O invested in 24 such entities through private debt, equity interests, and other securities. Many of these assets were harder to sell than the liquid securities normally held in open-ended investment funds. The Financial Conduct Authority later found that H2O had not carried out adequate due diligence on many of the investments and had weaknesses in its valuation procedures, risk controls, record keeping, and management of conflicts of interest. By August 2020, the assets later transferred into segregated side-pocket funds were valued at about €1.643 billion.
The events led to separate regulatory and court proceedings in the United Kingdom and France. In August 2020, the Autorité des marchés financiers requested the suspension of subscriptions and redemptions in three H2O UCITS funds, and H2O extended the suspension to five additional funds. The AMF later imposed financial sanctions on H2O and two former executives. In 2024, the FCA publicly censured H2O after finding breaches of three regulatory principles under a settlement in which the H2O Group had voluntarily secured €250 million for affected side-pocket investors. Later proceedings included a rejected UK judicial-review application, French administrative appeals, regulatory action against former H2O deputy CEO Jean-Noel Alba, an AMF sanction against fund custodian CACEIS Bank, and civil claims brought by thousands of investors in France.
H2O invested fund assets in 24 companies controlled by or introduced through Lars Windhorst. The investments included private placement debt and equity interests in early-stage or turnaround businesses, making many of the holdings less liquid than securities traded on public markets. The FCA found that half of the 24 investments had no record of due-diligence analysis when they were made. Ten had an Investment Decision Note, and seven of those also had a longer Investment Summary, although six of the seven summaries contained no risk analysis or evidence of independent valuation or financial analysis. Only two investments had any record of basic financial analysis.
Public reporting about H2O's exposure to Windhorst-linked investments appeared in June 2019 and was followed by substantial investor withdrawals. By mid-July, approximately €8 billion had been redeemed from the roughly €34 billion H2O managed at the start of June. The FCA sent information requests to H2O in August, October, and November as it examined how the firm selected, reviewed, and monitored the investments. The regulator later found that H2O supplied false or misleading information, created records for meetings that had not taken place, and provided investment research prepared after earlier transactions while presenting that research as work completed at the time.
On August 28, 2020, the AMF requested the suspension of subscriptions and redemptions in H2O Allegro, H2O MultiBonds, and H2O MultiStrategies because of their exposure to investments with valuation uncertainty. H2O then extended the suspension to five additional funds: H2O Adagio, H2O Moderato, H2O MultiEquities, H2O Vivace, and H2O Deep Value. During September and October, Windhorst-linked investments held by seven affected French UCITS funds were placed into segregated side-pocket funds closed to subscriptions and redemptions, while their other assets were transferred into open funds. The FCA later recorded the estimated value of the assets placed into the side pockets at approximately €1.643 billion as of August 2020.
The AMF Enforcement Committee fined H2O AM LLP €75 million and issued a reprimand over its management of seven French UCITS funds. Former CEO Bruno Crastes received a €15 million fine and a five-year ban from serving in the management roles covered by the AMF decision. Former chief investment officer Vincent Chailley received a €3 million fine and a reprimand. The proceedings addressed direct acquisitions of Tennor Group securities and buy-and-sell-back transactions, with findings concerning liquidity, valuation, investment limits, fund rules, and counterparty exposure.
Thousands of H2O fundholders brought civil claims in France against parties connected with the management, custody, auditing, and distribution of the affected funds. Defendants named in the litigation included H2O entities, CACEIS Bank, Natixis Investment Managers, and KPMG Audit, with other parties later added to the proceedings. The claimants included direct fundholders as well as some investors whose life insurance contracts contained units linked to the affected H2O funds. The civil action seeks compensation for alleged losses associated with assets that were separated into side-pocket funds in 2020.
On August 7, 2024, the FCA announced the outcome of its investigation and published details of a Final Notice dated August 2, 2024. The FCA imposed a public censure on H2O AM LLP after finding breaches of Principle 2, concerning skill, care, and diligence; Principle 3, concerning management and control; and Principle 11, concerning relations with regulators. Under the settlement terms, the H2O Group had voluntarily secured €250 million for current unitholders in the side-pocketed funds and formally waived rights to fees and investments totaling €320 million for their benefit. H2O AM LLP also agreed to apply voluntarily to cancel its UK regulatory permissions by December 31, 2024.
The FCA's findings also addressed H2O's controls over gifts, hospitality, and conflicts of interest. It found that H2O failed to record gifts and hospitality provided by Windhorst to H2O staff and their family members either at all or in sufficient detail. The FCA reported more than 50 instances in which hospitality had been received by H2O employees but had not been properly declared. Examples included meals, sporting events, private-jet travel, and use of a superyacht.
Collectif Porteurs H2O sought permission to pursue judicial review of the FCA's 2024 Final Notice. The investor group challenged the regulatory resolution associated with the €250 million arrangement for side-pocket unitholders. In February 2025, the High Court refused permission for the judicial-review claim to proceed. The FCA's Final Notice therefore remained in force without a full judicial-review hearing.
H2O AM LLP, Bruno Crastes, and Vincent Chailley challenged the AMF Enforcement Committee's 2022 sanctions before France's Conseil d'État. The court dismissed their applications on June 13, 2025. The €75 million sanction against H2O, the €15 million sanction and management ban imposed on Crastes, and the €3 million sanction against Chailley remained in place. The court also ordered payments toward the AMF's legal costs.
The FCA fined former H2O deputy CEO Jean-Noel Alba £1,049,500 and barred him from working in the UK financial-services industry. Alba had served as one of H2O's main contacts during the FCA investigation. The regulator found that he directed junior employees to create records for meetings that had not formally occurred and supplied investment research prepared after certain investments while presenting it as earlier work. The FCA later confirmed that Alba was the individual previously identified as "Senior Manager A" in the H2O Final Notice.
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning concerning its duties as custodian for seven French funds managed by H2O. The regulator identified deficiencies in controls involving investment ratios, valuations of unlisted securities, and compliance with restrictions contained in fund documents and financial regulations. CACEIS Bank filed an appeal with the Conseil d'État on February 26, 2026. The appeal concerns the custodian's regulatory responsibilities and is separate from the sanctions previously imposed on H2O and its former executives.
The civil action brought by H2O fundholders remained active in 2026. On April 17, the First President of the Paris Court of Appeal ordered the proceedings transferred to the Bobigny Commercial Court after grounds for recusal were identified concerning several judges involved in the case. Corporate disclosures from parties to the litigation continued to report thousands of claimants seeking compensation from H2O and other defendants. The transfer concerned the investor damages proceedings and did not reopen the completed FCA enforcement action against H2O.
In June 2026, H2O announced that it had completed the disposal of the remaining assets held in its side-pocket funds. The firm said the affected funds would be liquidated in July and that a final repayment of €135.7 million would follow earlier distributions made in January 2023 and March 2024. The repayment was scheduled to occur automatically for eligible unitholders. Liquidation of the remaining side-pocket assets did not end the separate civil claims being pursued by investors in France.
An asset management expert may review portfolio construction, investment approval procedures, concentration levels, liquidity controls, fund mandates, and the process used to select and monitor investments.
A valuation expert may examine private debt, unlisted securities, distressed holdings, valuation models, comparable transactions, cash-flow assumptions, discounts, and changes in the estimated value of assets over time.
A financial expert may assess governance systems, conflicts controls, gifts and hospitality procedures, committee records, internal monitoring, and communications with regulators.
A forensic accountant may reconstruct transactions, trace fund flows, reconcile trading and accounting records, analyze financial statements, and calculate claimed investor losses.
Investment files should record the information considered before a fund commits capital. That record may include company research, financial statements, valuation work, risk assessments, investment memoranda, and approval documents. The FCA found that many H2O investments had limited recorded analysis before they were made. It also found instances in which research prepared later was presented during the investigation as though it had existed when the original investment decisions were taken.
Open-ended funds may allow investors to redeem their units frequently, even when some portfolio assets cannot be sold quickly. When withdrawals increase, managers may need to sell the most liquid holdings first, leaving a larger share of harder-to-sell investments in the remaining portfolio. H2O's affected funds were suspended in 2020 after concerns arose over the valuation and liquidity of certain assets. The portfolios were then divided so that less-liquid holdings could be placed into separate side-pocket funds.
Written policies alone do not provide a complete record of potential conflicts. Firms also need systems that document gifts, meals, travel, entertainment, financial relationships, and other hospitality connected with people or companies involved in investment decisions. The FCA found repeated instances of hospitality involving H2O personnel and Windhorst that had not been properly declared. Those findings formed part of its broader review of H2O's conflict-management controls.
Documents given to regulators should accurately reflect what existed when the underlying decisions were made. Creating records after the fact or presenting later research as earlier analysis can lead to findings that are separate from the original investment conduct. The FCA's case against H2O covered both weaknesses in the firm's investment process and misleading information supplied during the investigation. Jean-Noel Alba later faced separate regulatory action over his role in providing records and information to the FCA.
The H2O dispute moved through several different legal channels. The FCA dealt with H2O's conduct as a UK-regulated asset manager, while the AMF pursued sanctions connected with French investment funds. Investors separately brought civil claims seeking compensation from H2O and other companies involved with the funds. Those proceedings involve different parties, legal standards, remedies, and procedural histories.
The regulatory proceedings produced several completed decisions. The AMF imposed sanctions on H2O, Bruno Crastes, and Vincent Chailley in 2022, and France's Conseil d'État rejected their challenges in 2025. The FCA censured H2O in 2024 under a settlement in which the H2O Group had voluntarily secured €250 million for current side-pocket investors, while former deputy CEO Jean-Noel Alba received a separate fine and industry ban the following year. CACEIS Bank was fined €3.5 million by the AMF in December 2025 and later appealed that decision. H2O announced the disposal of its remaining side-pocket assets and a final €135.7 million repayment in 2026, while separate investor damages litigation continued after its transfer to the Bobigny Commercial Court.
The H2O Asset Management matter developed through regulatory actions, court challenges, investor claims, and the eventual liquidation of side-pocketed assets. The FCA censured H2O in 2024 after finding failures in due diligence, management controls, conflict procedures, and communications with the regulator, while the AMF imposed separate sanctions in France against H2O and former executives. Later proceedings included the dismissal of challenges to the French sanctions, FCA action against Jean-Noel Alba, an AMF sanction against CACEIS Bank, and continuing civil claims by investors. By 2026, H2O had announced the disposal of its remaining side-pocket assets and a final repayment to eligible unitholders, while separate investor litigation in France remained ongoing.
What was the €250 million H2O investor arrangement?
Under the FCA's 2024 settlement, the H2O Group had voluntarily secured €250 million that was ring-fenced for payments to current unitholders in the side-pocketed funds. The H2O Group also formally waived rights to fees and investments totaling €320 million for the benefit of side-pocket fundholders. The FCA stated that H2O's conduct would ordinarily have justified a significant financial penalty, but imposing one would have reduced the funds available to those unitholders.
Why were H2O funds suspended in 2020?
On August 28, 2020, the AMF requested the suspension of subscriptions and redemptions in H2O Allegro, H2O MultiBonds, and H2O MultiStrategies because of their exposure to investments with valuation uncertainty. H2O then extended the suspension to five additional funds: H2O Adagio, H2O Moderato, H2O MultiEquities, H2O Vivace, and H2O Deep Value. During September and October 2020, the Windhorst-linked investments held by seven affected French UCITS funds were placed into side-pocketed funds closed to subscriptions and redemptions, while their other assets were moved into open funds.
What regulatory breaches did the FCA find against H2O?
The FCA found that H2O breached Principles 2, 3, and 11 of its Principles for Businesses. The findings included inadequate investment due diligence, deficiencies in governance and risk-management systems, weaknesses in conflicts-of-interest controls, and false or misleading statements and documents supplied to the FCA. The regulator also found that H2O created records and minutes for governance and oversight meetings, many of which had not taken place, and supplied later-prepared due diligence reports as evidence of earlier investment analysis.
What sanctions were imposed in France?
In its December 30, 2022 decision, the AMF Enforcement Committee fined H2O AM LLP €75 million and issued a reprimand. Bruno Crastes received a €15 million fine and a five-year ban from acting as a manager, directly or by delegation, or as an executive of the categories of regulated entities specified in the AMF decision. Vincent Chailley received a €3 million fine and a reprimand. On June 13, 2025, the Conseil d'État dismissed their challenges to the AMF decision.
An asset management expert may review portfolio construction, investment approval procedures, concentration levels, liquidity controls, fund mandates, and the process used to select and monitor investments.
A valuation expert may examine private debt, unlisted securities, distressed holdings, valuation models, comparable transactions, cash-flow assumptions, discounts, and changes in the estimated value of assets over time.
A financial expert may assess governance systems, conflicts controls, gifts and hospitality procedures, committee records, internal monitoring, and communications with regulators.
A forensic accountant may reconstruct transactions, trace fund flows, reconcile trading and accounting records, analyze financial statements, and calculate claimed investor losses.
Investment files should record the information considered before a fund commits capital. That record may include company research, financial statements, valuation work, risk assessments, investment memoranda, and approval documents. The FCA found that many H2O investments had limited recorded analysis before they were made. It also found instances in which research prepared later was presented during the investigation as though it had existed when the original investment decisions were taken.
Open-ended funds may allow investors to redeem their units frequently, even when some portfolio assets cannot be sold quickly. When withdrawals increase, managers may need to sell the most liquid holdings first, leaving a larger share of harder-to-sell investments in the remaining portfolio. H2O's affected funds were suspended in 2020 after concerns arose over the valuation and liquidity of certain assets. The portfolios were then divided so that less-liquid holdings could be placed into separate side-pocket funds.
Written policies alone do not provide a complete record of potential conflicts. Firms also need systems that document gifts, meals, travel, entertainment, financial relationships, and other hospitality connected with people or companies involved in investment decisions. The FCA found repeated instances of hospitality involving H2O personnel and Windhorst that had not been properly declared. Those findings formed part of its broader review of H2O's conflict-management controls.
Documents given to regulators should accurately reflect what existed when the underlying decisions were made. Creating records after the fact or presenting later research as earlier analysis can lead to findings that are separate from the original investment conduct. The FCA's case against H2O covered both weaknesses in the firm's investment process and misleading information supplied during the investigation. Jean-Noel Alba later faced separate regulatory action over his role in providing records and information to the FCA.
The H2O dispute moved through several different legal channels. The FCA dealt with H2O's conduct as a UK-regulated asset manager, while the AMF pursued sanctions connected with French investment funds. Investors separately brought civil claims seeking compensation from H2O and other companies involved with the funds. Those proceedings involve different parties, legal standards, remedies, and procedural histories.
The regulatory proceedings produced several completed decisions. The AMF imposed sanctions on H2O, Bruno Crastes, and Vincent Chailley in 2022, and France's Conseil d'État rejected their challenges in 2025. The FCA censured H2O in 2024 under a settlement in which the H2O Group had voluntarily secured €250 million for current side-pocket investors, while former deputy CEO Jean-Noel Alba received a separate fine and industry ban the following year. CACEIS Bank was fined €3.5 million by the AMF in December 2025 and later appealed that decision. H2O announced the disposal of its remaining side-pocket assets and a final €135.7 million repayment in 2026, while separate investor damages litigation continued after its transfer to the Bobigny Commercial Court.
The H2O Asset Management matter developed through regulatory actions, court challenges, investor claims, and the eventual liquidation of side-pocketed assets. The FCA censured H2O in 2024 after finding failures in due diligence, management controls, conflict procedures, and communications with the regulator, while the AMF imposed separate sanctions in France against H2O and former executives. Later proceedings included the dismissal of challenges to the French sanctions, FCA action against Jean-Noel Alba, an AMF sanction against CACEIS Bank, and continuing civil claims by investors. By 2026, H2O had announced the disposal of its remaining side-pocket assets and a final repayment to eligible unitholders, while separate investor litigation in France remained ongoing.
What was the €250 million H2O investor arrangement?
Under the FCA's 2024 settlement, the H2O Group had voluntarily secured €250 million that was ring-fenced for payments to current unitholders in the side-pocketed funds. The H2O Group also formally waived rights to fees and investments totaling €320 million for the benefit of side-pocket fundholders. The FCA stated that H2O's conduct would ordinarily have justified a significant financial penalty, but imposing one would have reduced the funds available to those unitholders.
Why were H2O funds suspended in 2020?
On August 28, 2020, the AMF requested the suspension of subscriptions and redemptions in H2O Allegro, H2O MultiBonds, and H2O MultiStrategies because of their exposure to investments with valuation uncertainty. H2O then extended the suspension to five additional funds: H2O Adagio, H2O Moderato, H2O MultiEquities, H2O Vivace, and H2O Deep Value. During September and October 2020, the Windhorst-linked investments held by seven affected French UCITS funds were placed into side-pocketed funds closed to subscriptions and redemptions, while their other assets were moved into open funds.
What regulatory breaches did the FCA find against H2O?
The FCA found that H2O breached Principles 2, 3, and 11 of its Principles for Businesses. The findings included inadequate investment due diligence, deficiencies in governance and risk-management systems, weaknesses in conflicts-of-interest controls, and false or misleading statements and documents supplied to the FCA. The regulator also found that H2O created records and minutes for governance and oversight meetings, many of which had not taken place, and supplied later-prepared due diligence reports as evidence of earlier investment analysis.
What sanctions were imposed in France?
In its December 30, 2022 decision, the AMF Enforcement Committee fined H2O AM LLP €75 million and issued a reprimand. Bruno Crastes received a €15 million fine and a five-year ban from acting as a manager, directly or by delegation, or as an executive of the categories of regulated entities specified in the AMF decision. Vincent Chailley received a €3 million fine and a reprimand. On June 13, 2025, the Conseil d'État dismissed their challenges to the AMF decision.
Are the H2O Asset Management proceedings still active?
Some proceedings have concluded, while others remained active in 2026. The FCA enforcement action against H2O has ended, and the Conseil d'État dismissed the challenges to the principal AMF sanctions in June 2025. Separate investor litigation continued in France, with a later 2026 Crédit Agricole disclosure reporting approximately 8,000 plaintiffs. CACEIS Bank also filed an appeal with the Conseil d'État on February 26, 2026, challenging the €3.5 million sanction and warning imposed by the AMF Enforcement Committee in December 2025.
Asset Valuation
Portfolio Valuation
Mutual funds
Financial Fraud
Internal Audit
Risk Assessment
Corporate Finance
Investment Fraud
Broker, +4
Finance
Forensic Accounting, +4
Finance
Are the H2O Asset Management proceedings still active?
Some proceedings have concluded, while others remained active in 2026. The FCA enforcement action against H2O has ended, and the Conseil d'État dismissed the challenges to the principal AMF sanctions in June 2025. Separate investor litigation continued in France, with a later 2026 Crédit Agricole disclosure reporting approximately 8,000 plaintiffs. CACEIS Bank also filed an appeal with the Conseil d'État on February 26, 2026, challenging the €3.5 million sanction and warning imposed by the AMF Enforcement Committee in December 2025.