SEC and French AMF Agreement Resumes U.S. Investment Adviser Registration Processing

The SEC and France’s Autorité des Marchés Financiers announced a supervisory memorandum of understanding on October 20, 2026 (Press Release 2026-108), providing for consultation and the exchange of supervisory information on advisers and funds operating in both markets.

 

The operative part is the registration path. The SEC said it will process new and pending applications from AMF-supervised asset management companies seeking to do business in the United States as investment advisers. An MOU of this kind is what allows the Commission to rely on the home regulator for information it cannot obtain directly, which is the condition for examining a firm whose books and records sit abroad.

 

For a French manager this makes Advisers Act registration a practical option rather than a theoretical one, with the ongoing obligations that follow: Form ADV, the compliance rule under Rule 206(4)-7, the custody rule where applicable, and examination by the Division of Examinations.

What the SEC and AMF Agreement Covers

The SEC and France's financial markets regulator, the AMF, entered into a memorandum of understanding to support consultation, cooperation, and information sharing. The agreement concerns certain investment advisers and investment companies regulated by the SEC and investment service providers supervised by the AMF that operate in the United States and France.

SEC to Resume Processing French Investment Adviser Applications

A central development is the SEC's announcement that it will process new and pending registration applications from AMF-supervised asset management companies seeking to conduct business in the United States as investment advisers. The arrangement is intended to facilitate registration and ongoing supervision through cooperation between the two regulators. Registration remains subject to applicable U.S. requirements.

How Cross-Border Regulatory Cooperation Will Work

The MOU establishes a framework through which the SEC and AMF can consult and exchange supervisory information about covered financial firms. This cooperation is intended to support regulatory oversight of investment businesses operating across both jurisdictions.

Information Sharing Between U.S. and French Regulators

The agreement provides a channel for the regulators to share relevant supervisory information. The announcement does not specify new reporting deadlines or additional compliance obligations for individual firms.

What French Asset Managers Should Consider

AMF-supervised asset managers considering U.S. investment advisory activities should evaluate whether SEC registration is required, review applicable U.S. regulatory obligations, and prepare the documentation needed for the registration process. Firms already operating across both markets should also consider how coordinated regulatory supervision may affect their compliance procedures.

How SJKP Can Help

SJKP can assist investment advisers, asset managers, and financial services companies with U.S. securities regulations, investment management compliance, and cross-border business matters. Foreign financial firms considering entry into the U.S. market can work with counsel to evaluate applicable registration requirements and regulatory obligations.