In light of the heightened emphasis on the Central Bank’s (CB) supervisory and enforcement role, companies that are required to comply with the Market Abuse Regulations (Regulations) should be prepared for CB investigations.

Such investigations by the CB could take the form of a general review of the company’s policy on disclosure of inside information; maintenance of insider lists; dealings by insiders; and clearance to insiders to deal. Alternatively, an investigation could involve a review of specific past dealings by insiders for example, at a time when there was volatility in a company’s share price.

William Fry is experienced in advising on compliance with the Regulations. If you require further information on preparing for a potential CB investigation, please contact one of the contacts listed below.

Contributed by Susanne McMenamin.

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