Notification obligation for market abuse (STR)

Investment firms are required to notify the AFM as soon as possible regarding a reasonable suspicion of market manipulation or trading with insider knowledge. The notification can be sent to

How can you report a suspicion of market abuse?

If you are an employee of an investment firm, you can find the Suspicious Transaction and Order Report (STOR) at the Portal AFM. You can also e-mail your notification to or notify the AFM by telephone at the Market Abuse Contact Point on +31 (0)20 797 3716. All notifications are treated as confidential.

After submitting the STOR, you will receive a copy of the form by e-mail as confirmation. After receipt of the form, the AFM will contact you within one week to verify the details with you. You can then pass on all the other information relevant to the notification to the AFM. A notification of suspected market abuse may lead to the AFM initiating an investigation.

Not obliged to notify?

We will be pleased to receive your notification even if you are not subject to a statutory obligation to notify market abuse.

What should you report in an STOR?

Suspicious orders (attempts to execute transactions) must be reported as well as suspicious transactions. A Suspicious Transaction Report (STR) must include the following information:

  • name and address of the contact person at the investment firm;
  • the capacity in which the investment firm acted in the matter;
  • the name of the issuing institution involved;
  • the reason for the notification;
  • a description of the financial instruments involved in the transaction concerned;
  • the nature of the transaction;
  • the date and place of execution of the transaction(s);
  • the price and size of the transaction(s);
  • whether the transaction was for the customer’s own account or for a third party;
  • relevant tapes or documents;
  • any other information that could reasonably be significant for an investigation by the AFM.

If this information is not available, or not immediately, state in any case the reason for the suspicion of market abuse. It is important that market abuse is reported to the AFM without delay. Make sure that all the relevant tapes of conversations and documents regarding the notification are retained.

Duty of confidentiality of the AFM and the notifying party

The AFM assesses whether a notification of suspected market abuse gives grounds for initiating an investigation. During the investigation, the AFM cannot make any statements regarding its investigation due to its duty of confidentiality. The investment firm is also not allowed to make any statements to its customer regarding the notification to the AFM.

Supervision of notification of market abuse

The AFM may take measures if an investment firm has failed to meet its obligations regarding the notification of market abuse to the AFM. The AFM may issue an instruction, impose an order for incremental penalty payments or impose a fine on an investment firm. The AFM may also refer the matter to the Public Prosecution Service (“OM”). The AFM determines which measure is appropriate in each individual case.

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