Public statement relating to Settlement Agreement between the Central Bank of Ireland and J&E Davy

Date02 March 2021
Central Bank of Ireland
J&E Davy
J&E Davy fined €4,130,000 and reprimanded by the Central Bank of Ireland for regulatory
breaches arising from personal account dealing
On 1 March 2021, the Central B ank of Ireland (the Central Bank) reprimanded and fined J&E
Davy (Davy) €4,130,000 in respect of four breaches of the European Communities (Markets in
Financial Instruments) Regulations 2007 (the MiFID Regulations) that occurred over different
intervals between July 2014 and May 2016.
The Central Bank’s investigation arose from a transaction a group of 16 Davy employees (the
Consortium) undertook in a personal capacity with a Davy client (the Client) in November 2014
(the Transaction). Within the Consortium was a group of senior executives (the Committee). In
permitting the Transaction, Davy prioritised facilitating an opportunity for the Consortium to
make a personal financial gain over ensuring that it was complying with its regulatory
obligations. The Transaction highlighted a weak internal control framework within Davy in
relation to conflicts of interest management and personal account dealing. All of this served to
create an elevated risk of investor detriment.
Following details about the Transaction becoming public four months after it occurred, Davy
contacted the Central Bank to provide an explanation. At that stage, Davy failed to disclose the
full extent of the wrongdoing. This lack of candour was treated as an aggravating factor in this

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