In December 2019, the Financial Conduct Authority (FCA) fined a former PDMR of Braemar Shipping Services plc (a premium listed company) for failing to announce transactions in the company's shares in accordance with Article 19 of the Market Abuse Regulation (MAR). This is the first enforcement action in connection with the PDMR dealing provisions in MAR.
The PDMR in question was notified of his obligations under MAR on 22 July 2016. This included a memorandum on MAR, the Braemar Share Dealing Policy and Code and a memorandum on inside information. It also included a form to sign, confirming he had read and understood the contents. The PDMR confirmed receipt of these documents on 24 August 2016, but did not return the signed form until November 2016. He had dealt twice in Braemar shares in the intervening period and did not inform the company or FCA of those transactions.
The PDMR dealt again on 18 January 2017, notifying the company of this transaction on 24 January 2017 only after receiving an email addressed to all PDMRs reminding them of the need to seek clearance prior to dealing. The company announced the transaction to the market and notified the FCA on 25 January 2017.
Braemar itself has not been sanctioned or fined by the FCA.
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