As you are all aware, MAR is now live. We hope you are all ready, and the new regime has been implemented throughout your organisations.
Even if your organisation has everything fully implemented, we would recommend that you still ask yourself the following questions:
- Do you have your policies and procedures in place?
- Do you have the right culture and conduct to prevent market Abuse taking place?
- Do you have the appropriate systems and controls to detect Market Abuse?
- Do you have the appropriate skills and processes to handle Whistleblowing and Suspicious Transaction and Order Reports (STOR)?
- Do your procedures create an appropriate audit trail to satisfy the regulator, and protect yourself and your organisation?
Speaking at our recent breakfast briefing, Jonathan Herbst from Norton Rose Fulbright made some key points that are worth due consideration:
“It’s what you do on an on- going basis that makes the difference. The regulator is after both the individual and the firm. MAR is a re-emphasis on both systems and controls. You can have automated and human surveillance systems but the actual monitoring has to be done by the firm – you can’t outsource it”.
The training of staff on the new regime is not only imperative, but also fundamental when learning how to complete the new STOR template. Have you provided sufficient training for your staff?
It is a recognised fact that whilst one off training meets the requirements, ongoing training is far more effective. Would your employees benefit from ongoing training?
We believe responding to Market Abuse in the right way is extremely important. That’s why Market Abuse Regulation was featured as a key topic in our first Breakfast Briefing on the 4th July.
FSTP and our partners can provide you with ongoing training throughout the year, so that all your employees maintain their awareness of the MAR regime. Please contact us to discuss these options.