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STOR Form Template

SUSPICIOUS TRANSACTION OR ORDER REPORT – TEMPLATE

 
SECTION 1 – IDENTITY OF FIRM/PERSON SUBMITTING THE STOR:
Full Name of Person:
Position in Company:
Company Name (if applicable):
Full Address of Reporting Person:
Full Company Address (if different):
Acting Capacity Regarding Suspicious Activity: [Description of the capacity in which the reporting entity was acting with regards to the suspicious orders and/or transactions, e.g. executing orders on behalf of clients, dealing on own account, operating a trading venue etc.]
Type of Activity & Type of Instrument Traded:
Relationship to Suspected Person or Entity:
Contact Details for Additional Information or Follow-Up: [Person to be contacted within the reporting entity for additional request for information relating to this report (e.g. compliance officer) and relevant contact details:

– First name(s) and surname(s);

– Position of the contact person within the reporting entity;

– Professional email address.]

 
SECTION 2 – TRANSACTION OR ORDER DETAILS:
Description of Financial Instrument: [Describe financial instrument of STOR specifying:

– The full name or description of the financial instrument;

– The instrument identifier code as defined under delegated acts adopted under Article 26 of Regulation (EU) No 600/2014 when applicable or other codes;

– The type of financial instrument according to the taxonomy used to classify the financial instrument and the associated code (ISO 10962 CFI code).]

[Additional elements for orders and transactions relating to OTC derivatives (The list of data below is not exhaustive)

– Describe the type of OTC derivative (e.g. CFD, swap, CDS, OTC option) using the type identified under Article 4(3)(b) of

Commission Implementing Regulation (EU) No 1247/2012.

– Describe the characteristics of the OTC EN 286 EN

ESMA REGULAR USE derivative including at least, where relevant to the particular derivative type, the following:

– nominal amount (face value);

– currency of the price denomination;

– maturity;

– premium (price);

– interest rate.

– Describe at the least the following, where relevant for the particular type of OTC derivative:

– Margin, up-front payment and nominal size or value of underlying financial instrument;

– Transaction terms such as the strike price, the contract terms (e.g. spread bet gain/loss per tick move).

– Describe the underlying financial instrument of the OTC derivative specifying:

– The full name of the underlying financial instrument or description of the financial instrument;

– The instrument identifier code as defined under delegated acts adopted under Article 26 of Regulation (EU) No 600/2014 when applicable or other codes;

– The type of financial instrument according to the taxonomy used to classify the financial instrument and the associated code (ISO 10962 CFI EN 287 EN ESMA REGULAR USE

code).]

Date/Time of Suspicious Activity: [Indicate the date(s) and time(s) of the order(s) and/or transaction(s) specifying the time zone.]
Market Where Activity Occurred: [Specify:

– name and code to identify the MiFID trading venue, the systematic internaliser or the organised trading platform outside the Union where the order was placed and the

transaction was executed as defined under delegated acts adopted under Article 26 of Regulation (EU) No 600/2014 or,

– if the transaction was not executed on any of

the above-mentioned venues,

Location: [Full name of the country and the ISO 3166-1 two-character country code.]

[Specify:

-where the order is given (if available);

-where the order is executed.]

Description of Order/Transaction: [Describe at least the following characteristics of the order(s) or the transaction(s) reported:

– Transaction/Order reference number (if applicable);

– Settlement date and time;

– Purchase price/sale price;

– Volume/quantity of financial instruments

[Where there are multiple suspicious orders or transactions, the details on the prices and volumes of such orders and

transactions can be provided to the competent authority in an Annex to the STOR.]

– Information on the order submission, including at least the following:

– type of order e.g. “buy with limit €x”;

– the way the order was placed e.g. electronic order book;

– the timing when the order was placed;

– the person who placed the order;

– the person who received the order;

– the means by which the order is transmitted.

– Information on the order cancellation or alteration (if any):

– The time of the alteration and/or cancellation;

– The person who altered and/or cancelled the order;

– The nature of the alteration (e.g. change in price or quantity) and the extent of the alteration;

[Where there are multiple suspicious orders or transactions,

the details on the prices and volumes of such orders and

transactions can be provided to the competent authority in an

Annex to the STOR.]

– The means to alter the order (e.g. via e-mail, phone, etc.).]

 
SECTION 3 – DESCRIPTION OF THE NATURE OF THE SUSPICION:
Nature of the Suspicion: [Specify the type of breach the reported orders or transactions could constitute:

– market manipulation;

– insider dealing;

– attempted market manipulation;

– attempted insider dealing.]

Reason for the Suspicion: [Narrative text to describe the activity (transactions and orders, way of placing the orders or executing the transaction and characteristics of the orders and transactions that make them suspicious) and how the matter came to the attention of the reporting person, and to specify the reasons for suspicion.

As non-exhaustive guiding criteria, the description may include:

– for financial instruments admitted to trading on/traded on a trading venue, a description of the nature of suspicious order book interaction/transactions;

– for OTC derivatives, details concerning transactions or orders placed in the underlying asset and information on any possible link between dealings in the cash market of the underlying asset and the reported dealings in the OTC derivative.]

 
SECTION 4 – IDENTITY OF FIRM/PERSON SUSPECTED:
Full Name of Person:
Date of Birth:
National Identification Number (if applicable):
Address;
Details about Employment: [Information about the employment of the suspected person, from information sources available internally to the reporting entity (e.g. account documentation in case of clients, staff information system in case of an employee of the reporting firm).]
Account Number(s): [Numbers of the cash and securities account any joint accounts or any Powers of Attorney on the account the suspected entity/person holds.]
Client Identifier under Transaction Reporting Pursuant to MiFIR (or any other code of identification): [In case the suspected person is a client of the reporting entity.]
Relationship with Concerned Issuer (if known or applicable):
 
SECTION 5 – ADDITIONAL INFORMATION:
Background or any other information considered by the reporting entity relevant to the report
[The list below is not exhaustive.

– The nature of the suspected entity/person (e.g. retail client, institutions);

– The nature of the suspected entity’s/person’s intervention (on own account, behalf of a client, other);

– The size of the suspected entity’s/person’s portfolio;

– The date on which the business relationship with the client started if the suspected entity/person is a client of the reporting person/entity;

– The type of activity of the trading desk, if available, of the suspected entity;

– Trading patterns of the suspected entity/person. For guidance, the following are examples of information that may be useful:

– trading habits of the suspected entity/person in terms of use of leverage and short selling, and frequency of use;

– comparability of the size of the reported order/transaction with the average size of the orders submitted /transactions carried out by the suspected entity/person for the past 12 months;

– habits of the suspected entity/person in terms of the issuers whose securities it has traded or types of financial instruments traded for the past 12 months, in particular whether the reported order/transaction relates to an issuer whose securities have been traded by the suspected entity/person for the past year.

– Other entities/persons known to be involved in the suspicious activity:

– Names;

– Activity (e.g.. executing orders on behalf of clients, dealing on own account, operating a trading venue, systematic internaliser, etc.).]

 
SECTION 6 – DOCUMENTATION ATTACHED:
[List the supporting attachments and material provided with this STOR. Examples of such documentation are e-mails, recordings of conversations, order/transaction records, confirmations, broker reports, Powers of Attorney documents, and media comment if relevant.

When the detailed information about the orders/transactions of Section 2 of this template is provided through a separate annex, indicate the name of that annex.]