Regulatory Alerts2018-06-29
FMA Circular on Personal Transactions by Employees with Financial Instruments under MiFID II Delegated Regulation (EU) 2017/565
The Austrian Financial Market Authority requires credit institutions and other legal entities to implement documented written arrangements with control measures for monitoring employees' personal transactions involving financial instruments. These arrangements mandate a broad scope of relevant persons, prompt notification on the same or following banking day, and comprehensive reporting that covers all transactions regardless of account type or monetary threshold. Legal entities must also conduct timely material checks against watch and black lists, ensuring that both reporting obligations and transaction validity are continuously verified to prevent conflicts of interest.
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