Karen Pignet-Aiach, Gad Aiach, Michaël Chetrit and Mikostart Fine - €700,000 - AMF - May 2025

Quick facts

• Amount: € 700,000
• Date: 5-May-25
• Violations: Insider Dealing
• Violation Period: 10-12 February 2021

Fine Overview

The AMF's Sanctions Committee found that Mme Karen Pignet-Aiach, co-founder and then CEO of Lysogene, possessed privileged information regarding the FDA's approval for LYS-GM101 clinical trials by 7:29 PM on February 10, 2021. This information was deemed precise, not publicly known, and likely to have a significant influence on Lysogene's stock price.    

Mme Pignet-Aiach was found to have illicitly disclosed this information to her ex-husband, M. Gad Aiach.  M. Aiach then used this information to acquire Lysogene shares for his own account and for the company Vestingene.  He also recommended that another individual, Mme B, acquire Lysogene shares based on this privileged information and illicitly disclosed the information to M. Michaël Chetrit.  M. Chetrit and his company, Mikostart, subsequently used this information to acquire Lysogene shares.    

Lysogene had announced on February 12, 2021, before market opening, that it had received FDA approval to begin clinical trials for LYS-GM101, a treatment for GM1 gangliosidosis.  The information was considered privileged from ~7:00 PM on February 10, 2021, until its public disclosure.  

Details of the Fine

Information Possession

• Mme Pignet-Aiach received confirmation of the FDA approval via an email from a Lysogene employee at 7:21 PM on February 10, 2021, following a phone call from the FDA around 7:00 PM the same day.  The official FDA approval letter was emailed to Lysogene at 7:47 PM.
   

• Evidence, including deleted messages and the use of encrypted messaging apps like Signal, pointed to Mme Pignet-Aiach communicating the privileged information to M. Aiach around 7:44 PM on February 10, 2021.  
• M. Aiach, despite being hospitalized and under morphine at the time, proceeded to place urgent buy orders for Lysogene shares for his company GA Invest (later executed for his personal account due to administrative reasons) that evening and confirmed further purchases for himself and Vestingene on February 11, 2021.
  
  

• M. Aiach recommended to Mme B on the evening of February 10, 2021, to acquire Lysogene shares, suggesting a "position to take first thing tomorrow" and advising discretion.  
• He also communicated with M. Chetrit. M. Chetrit, for Mikostart, acquired a significant number of Lysogene shares on February 11, 2021.  These transactions were considered atypical in terms of amount and timing compared to their usual investment patterns.
  
  

• Following the public announcement on February 12, 2021, Lysogene's stock price rose, opening at €3.5 (a 4.5% increase) and reaching up to a 21% increase during the session, closing at €3.68 (a 9.85% increase).    
  
  

The defense arguments, such as the transactions being based on personal analysis of public information (like a previously announced state-guaranteed loan or the effects of morphine), were not found convincing by the Sanctions Committee.  

Chronology

BREAKDOWN of the Fine

The AMF Sanctions Committee imposed the following pecuniary sanctions:

• Mme Karen Pignet-Aiach: €150,000 for illicitly disclosing privileged information.    
• M. Gad Aiach: €400,000 for using privileged information, recommending its use, and illicitly disclosing it.    
• M. Michaël Chetrit: €50,000 for using privileged information.    
• Mikostart: €100,000 for using privileged information.  

Select Quotes

• “L’empressement de M. Aiach à acquérir des titres Lysogene […] constitue un indice de détention et de transmission de l’information privilégiée.” 
  • “Mr Aiach’s eagerness to buy Lysogene shares … is an indication that he possessed and passed on the inside information.”
• “Le manquement à l’obligation d’abstention d’utilisation d’information privilégiée […] est caractérisé à l’égard de M. Chetrit et Mikostart.” 
  • “The breach of the obligation to refrain from using inside information … is established in respect of Mr Chetrit and Mikostart.”

Sources

• AMF - Press Release
• AMF - Case Detail - SAN-2025-04 - Décision de la commission des sanctions du 5 mai 2025 à l'égard de la société Mikostart, de Mme Karen Pignet-Aiach et de MM. Gad Aiach et Michaël Chetrit