On 12 July, the Central Bank of Ireland (Central Bank) published a series of findings and Dear CEO letters on compliance with the Market Abuse Regulation (MAR). The letters are not confined to regulated firms and issuers but are also addressed to advisors who act on behalf of, or on account of, issuers.
The findings recognise some good practices; however they also identify a need for significant improvements and call for immediate steps to be taken. A number of risk mitigation programmes (RMPs) have been issued to certain market participants where specific concerns were identified requiring remediation within a period specified by the Central Bank to those market participants. In addition, all market participants have been required to critically assess their MAR framework in light of the Central Bank findings, to put in place a time bound plan to remediate deficiencies, and to have such plan discussed and approved by boards by the end of 2021. This is a significant supervisory step and can, in certain cases, be a precursor to enforcement.