Ava Capital Markets Limited

Background In 2011 the Central Bank identified a number of issues with transaction reports submitted by the Firm. As a result of this, the Firm conducted a historical analysis of its transaction reports, and in January 2012 the Firm notified the Central Bank that a considerable number of transaction reporting failures had been discovered. From July 2009 to July 2011, the Firm relied on a transaction reporting system the development of which had been outsourced to an external service provider. The transaction reporting failures have now been rectified by the Firm. The Firm’s internal IT department has redeveloped the Firm’s transaction reporting system and the Firm no longer outsources this function. Penalty decision factors The penalties imposed in this case reflect the importance the Central Bank places on accurate and timely reporting of all regulatory information. In this case, the information comprised transactions in financial instruments under the MiFID Regulations. In deciding the appropriate penalties to impose, the Central Bank has taken the following into account: 3  the seriousness with which the Central Bank views any contravention of the MiFID Regulations;  the number of transactions concerned;  that the Firm has taken appropriate remedial steps to rectify the contraventions and causes thereof; and  the cooperation of the Firm during the investigation and in settling at an early stage in the administrative sanctions procedure. The Central Bank confirms that the matter is now closed.