SEC and AMF announce supervisory MoU to enhance cooperation for investment advisers and investment service providers

For firms with dual US and French/EU exposure, this signals closer coordination on cross-border supervision, with supervisory expectations likely to converge around licensing, conduct and disclosure standards. Compliance teams should treat the MoU as a prompt to review the consistency of their regulatory representations across both jurisdictions, particularly where the same advisory or distribution activity is supervised by both authorities. Action items: map entities and activities falling within each regulator's remit; confirm that policies, disclosures and client onboarding documentation are accurate under both regimes; and stress-test reporting and record-keeping capabilities against potential joint or parallel information requests.

There is no immediate new substantive rule or deadline, so this is a supervisory-signal item rather than a compliance change. Firms should expect faster and more direct regulator-to-regulator dialogue, which raises the stakes on accurate and timely responses to supervisory enquiries in either jurisdiction. Competitive opportunity exists for groups with well-integrated cross-border compliance frameworks, which should find bilateral supervisory engagement more predictable.

Global groups should brief senior management and update cross-border cooperation protocols accordingly.