Finnish Financial Supervisory Authority Imposes First Administrative Sanctions Related To MAR Managerial Transactions’ Notifications

• FIN-FSA issued its first administrative sanctions related to MAR managerial transactions' notifications – penalty payments ranging from EUR 7,000 to EUR 30,000 were imposed on three companies for delays in transaction notifications

• FIN-FSA enforces the transaction notification obligations strictly and is likely to impose penalties for any failures in adhering to the obligations

• Market participants should pay close attention to correct timing of their trading activities

The FIN-FSA has on 17 October 2024 published three administrative sanctions regarding the obligations of managers of listed companies and their closely associated persons under Article 19 of the Market Abuse Regulation ((EU) No 596/2014, "MAR"). These obligations require notification to the FIN-FSA and the listed company of transactions related to the securities of said listed companies, once a total amount of EUR 5,000 has been reached within a calendar year.  

The FIN-FSA has imposed penalty payments on three closely associated companies due to the delays in their transaction notifications, which exceeded the mandatory three banking day notification period. The delays in transaction notifications ranged from nearly two months to a year. The penalty payments varied between EUR 7,000 and EUR 30,000. According to the FIN-FSA, these amounts were determined based on an overall assessment that particularly considered the length, nature and extent of the failures to report. For example, later self-correction of the failure to notify transactions reduced the amount of the penalty payment but did not exempt the companies in question from the penalty entirely. Based on these decisions, the FIN-FSA enforces the transaction notification obligations strictly and is likely to impose penalties for any failures in adhering to the obligations – even a voluntary correction does not prevent enforcement actions.

Please note that transaction timing is crucial – observe factors such as closed windows and potential insider projects. Additionally, even if trading is technically permissible, it may not always be advisable if the likely public perception of one’s trading activity would be negative.

We at Hannes Snellman constantly monitor the interpretation practices and enforcement actions of the FIN-FSA regarding potential infringements. We are happy to assist market participants in connection with any financial regulatory matters.

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