RegSol Blog


Central Bank of Ireland (CBI) Dear CEO Letters on Market Abuse

July 2021

In line with the Market Abuse Regulations (MAR), the Central Bank has issued Dear CEO letters from March 2019 to July 2021. These letters were issued to dozens of companies including Investment firms or persons who engage in the transmission or execution of orders, issuers or persons who act on behalf of issuers, highlighting initial expectations and subsequently breaches of the MAR.

Following initial publication of its findings in 2020, based on supervisory activity from 2019 the CBI highlighted the following failings leading to breaches of the Regulations:

  • Ineffective trade surveillance systems
  • Lack of monitoring and supervision on all outsourced activity
  • No clear lines of responsibility for staff
  • Inadequate reporting of Suspicious Transaction and Order Reports (STOR)
  • Lack of governance around communication to staff on unlawful disclosing of inside information and insider dealing

In its most recent publication and Dear CEO Letter on July 12th, 2021, the CBI expects:
  • Trade surveillance and STOR reporting frameworks must be enhanced to ensure that controls and processes in place are more robust.
  • Enhanced frameworks to ensure that public disclosures of information are made timely
  • Insiders to be reminded of their MAR obligations and the consequences of market abuse
  • Improvements on the quality of insider lists and governance on how they are operated
  • Staff awareness and training to be increased and enhanced.

It is anticipated that work will continue for many firms and individuals well into 2022, where Regulators will enhance their scrutiny on firms to complete these actions as soon as possible.

Director General Financial Conduct, CBI - Derville Rowland, said:

“Misconduct on securities markets undermines transparency and trust among market participants and is detrimental to investor protection. MAR is a critical component in deterring misconduct and identifying market abuse where it occurs. This represents our most comprehensive review of MAR compliance to date, encompassing regulated trading firms, issuers and issuers’ advisors.’’

For further details, please refer to the following link:
Central Bank publishes findings of review into market abuse risks

Seán Wallace

Regulatory Compliance Consultant