The Central Bank takes action against Alan Dalton for breaches of Market Abuse Regulation

Although the action targets an individual and the issuer is not under investigation, it is a clear supervisory signal that the CBI will pursue personal accountability for trading on material non-public information. For compliance teams, the case reinforces the need to maintain robust MNPI identification and handling processes, personal account dealing restrictions, closed-period controls, pre-clearance, surveillance of employee trades, and demonstrable training for insiders. Firms should review whether current controls cover former employees and leavers, particularly where shareholdings or vesting arrangements continue.

Listed issuers should ensure insider lists are accurate and timely, and that disclosure and escalation protocols operate effectively. Broker-dealers and wealth managers should test order and trade surveillance for suspicious patterns around issuer announcements and consider enhanced due diligence where clients are insiders. The absence of action against the company is not a reason for complacency: supervisors expect firms to evidence a culture of compliance and to act on red flags.

Immediate steps include a targeted review of insider-dealing controls, refresher training for restricted persons, and board-level discussion of enforcement trends. This is a significant compliance reminder rather than a new rule change; no new filing deadline is created.