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Cathrine Modig

New guidelines for administrative sanctions for late insider reporting

The Swedish Financial Supervisory Authority (Sw. Finansinspektionen) has issued new guidelines for administrative sanctions for late insider reporting according to EU’s Market Abuse Regulation (MAR), see the following link (in Swedish): Riktlinjer för sanktionsavgifter vid sen insynsrapportering.

The guidelines contain among others a chart with model rates to be used as a basis in relation to the issue of administrative sanctions. The Swedish Financial Supervisory Authority will take the size of the transaction and the duration of the delay into account in their assessment. The guidelines will be applied to notifications submitted (and not to omitted notifications discovered by the Swedish Financial Supervisory Authority, which are expressly not covered by the guidelines).

The guidelines will provide greater clarity and predictability as regards the ‘normal’ case of late insider reporting.