meta_id 3411446

On August 13, 2026, Denmark's Financial Supervisory Authority (Finanstilsynet) issued an enforcement order to Danske Bank A/S requiring it to bring its handling of insider lists for external issuer clients into compliance with Article 18 of Regulation (EU) No. 596/2014 on market abuse (Market Abuse Regulation) and Article 1 and Annex I, Model 1 of Commission Implementing Regulation (EU) No. 2022/1210. Danske Bank identified deficiencies in its electronic system for managing insider lists for external issuer clients in 2018. The bank notified Finanstilsynet in spring 2023 that it was not fully complying with insider list requirements under the Market Abuse Regulation regarding external issuer clients. Following dialogue between the bank and Finanstilsynet on remediation, Danske Bank conducted additional controls and identified further errors in its insider list management. Finanstilsynet determined that Danske Bank continued to fall short of all requirements for correctly maintaining insider lists. Insider lists serve as a critical safeguard for market integrity, enabling issuers and persons acting on their behalf to monitor the flow of inside information, prevent unauthorised disclosure, and mitigate insider trading risks. The lists also facilitate rapid identification of persons with access to inside information and the dates of such access, supporting market abuse investigations. Finanstilsynet concluded that the scope and duration of Danske Bank's deficiencies in registering insiders for external issuer clients could have compromised market integrity. Danske Bank has since remedied the deficiencies identified in the enforcement order.