Goodbody Stockbrokers Unlimited Company

The Central Bank has determined the appropriate fine to be €1,750,000, which was reduced by 30% to €1,225,000 by way of a settlement discount. 1 “Arrangements, systems and procedures” can include putting in place, where applicable, an automated trade surveillance system that monitors for market abuse, but can also include the requirement to have the necessary policies, governance and appropriate human analysis and oversight. Firms must ensure that what they put in place in terms of monitoring is appropriate and proportionate to the scale, size and nature of their business activity. 2 “Suspicious orders and transactions” relate to orders or transactions that could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, which all amount to market abuse. Where firms form a reasonable suspicion that insider dealing, market manipulation or attempted insider dealing or market manipulation has occurred, they are obliged under Article 16(2) to report the suspicion to the Central Bank via a Suspicious Transaction and Order Report (STOR). A “transaction” refers to the buying or selling of financial instruments (such as stocks, bonds, derivatives, etc). An “order” refers to the instruction to buy or sell a financial instrument at a particular price and quantity.