Skip to content
Blockchain Posts

regulation

SEC and AMF sign supervisory MOU on cross-border asset managers

The SEC and France's AMF signed a cooperation MOU covering investment advisers, investment companies and investment service providers operating across the two markets.

by 4 min read
regulationpolicysecamfcross-border

The SEC and the French Autorité des marchés financiers (AMF) announced a supervisory Memorandum of Understanding (MOU) on October 20, 2026, formalising information-sharing and consultation on firms that cross between the two markets, per SEC Press Release 2026-108.

What it covers

The MOU is a supervisory arrangement — the operational layer below the two agencies' earlier 1989 Enforcement MOU and the IOSCO MMoU, both of which deal with cross-border investigations. The new one is forward-looking: it governs day-to-day oversight of firms that are regulated on both sides of the Atlantic.

In scope:

  • US-registered investment advisers that the SEC oversees.
  • US-registered investment companies (funds) with French-regulated managers or service providers.
  • AMF-supervised investment service providers (ISPs) — the French equivalent of a broker-dealer or portfolio manager — that want to do business in the US.
  • AMF-supervised asset management companies seeking to register with the SEC as investment advisers.

The release describes the MOU as "facilitating" that last pathway: SEC staff will process new and pending registration applications from AMF-supervised asset managers under its terms, with the AMF supplying the home-country supervisory record.

What it does not cover

The press release does not mention crypto, digital assets, tokenisation or stablecoins. The MOU is scoped to investment advisers, funds and investment service providers, not to the SEC's crypto rulemaking or the AMF's PSAN/MiCA perimeter. Firms whose primary activity is operating a trading venue, custody for digital assets or stablecoin issuance would need a separate arrangement — one which, so far, neither agency has announced.

That omission is notable because the AMF has been the EU regulator most publicly engaged on MiCA implementation gaps, and because the SEC has used bilateral tools to work around what it has called "regulatory arbitrage" by crypto venues. The MOU, as described, keeps the French-US regulatory conversation on traditional-finance footings.

Signatory statements

  • SEC Chairman Paul S. Atkins: "This MOU exemplifies the necessary spirit of cooperation in securities regulation."
  • AMF Chair Marie-Anne Barbat-Layani: welcomed the MOU as a step in "strengthening cooperation between the two authorities."

The release names no separate signing event; the MOU is dated the same day as the press release.

Why it matters

Two reasons the agreement reads bigger than its narrow scope:

  1. The SEC is thinning out bilateral MOUs under the Atkins chair as it tries to streamline cooperation with large markets. The France MOU is the second major European arrangement this year, after the SEC's September working arrangement with the FCA on consolidated supervision of UK-regulated advisers.
  2. The AMF is France's gateway for US fund managers wanting EU distribution of UCITS and AIF products, and vice versa. Formalising information flow at the asset-manager tier means less friction on dual-registered firms — including some that will eventually bring tokenised fund products into both jurisdictions.

What to watch

  1. Follow-on crypto MOU. The release's silence on digital assets is the obvious gap. Both agencies have active rulemaking on tokenised securities — the SEC's TSV sandbox, the AMF's input into the ESMA MiCA technical standards. A separate scope-crypto MOU is the plausible next move.
  2. AMF-supervised managers in SEC's queue. The MOU should accelerate pending Form ADV registrations from French asset managers. Firms waiting on dual-registration (several large French listed asset managers plus a handful of crypto-specialist managers running SEC-registered feeder funds) are the test cases.
  3. SEC-FSA parallel. Press Release 2026-107 covers the SEC's autumn dialogue with Japan's FSA on similar supervisory topics — including, per that release, crypto-asset supervision. The France MOU's narrower scope is a deliberate choice.

Context

The MOU is the first formal supervisory arrangement between the SEC and the AMF since the agencies updated their enforcement cooperation in 2020. It arrives against a backdrop of two divergent regulatory stances on digital assets — the SEC under Atkins has leaned permissive on tokenised equities, while the AMF has pushed EU-wide for stricter stablecoin reserve rules. The MOU papers over the shared traditional-finance perimeter where they still agree.

Sources:

Related stories