By: Susanne McMenamin & Anna O’Carroll (Matheson)
The Central Bank of Ireland (the “CBI“) recently published its Securities Markets Risk Outlook Report 2023 (the “Report“) and while the focus is on informing regulated financial service providers, investors and market participants of the key risks and areas of focus for markets supervision, which will inform the CBI’s supervisory engagements over the coming year, it also contains updates and guidance to listed companies with regard to MAR. See Matheson’s general update on the Report here.
In the Report, the CBI highlighted that it continues to observe ineffective frameworks and controls for the management of inside information and the maintenance of insider lists. As outlined in its MAR thematic review industry communication regarding inside information (July 2021), issuers are required to ensure compliance with all elements of MAR regarding insider lists. To ensure compliance with all aspects of Article 18 of MAR, issuers should have frameworks, including comprehensively evidencing how access to inside information is controlled. Failure to comply may result in the CBI taking action, up to and including enforcement…