20th Anniversary of the IOSCO MMoU

Enforcement Successes Involving MMoU Cooperation

Cooperation under the IOSCO MMoU has enabled the successful investigation of capital markets violations and the execution of enforcement actions in cross-border contexts, where jurisdictional limits would have led to a different outcome. Below are a few examples of cases where assistance provided by overseas counterparts was not only instrumental, but also critical in arriving at positive enforcement outcomes for MMoU signatories:

Commissione Nazionale per le Società e la Borsa, Italy

• MMoU Cooperation with an Overseas Counterpart Led to the Imposition of Administrative Sanctions on Entities in the Two Jurisdictions in a Market Manipulation Case
  Decision No 21616 of 3 December 2020
• MMoU Cooperation with an Overseas Counterpart Led to the Imposition of Pecuniary Administrative Sanctions on Entities in the Two Jurisdiction in an Insider Trading Investigation
  Decision No 21044 del 12/09/2019
• MMoU Cooperation with an Overseas Counterpart was Essential in an Insider Trading Investigation that Led to the Application of Administrative Sanctions on a Violator
  Decision No 20502 of 28 June 2018
• Information Provided by two Overseas Counterparts was Instrumental in Imposing Insider Trading Administrative Sanctions on a Resident of the Second Jurisdiction who operated Through a Bank based in the Third Jurisdiction
  Decision No 19902 of 8 March 2017
• MMoU Cooperation with a Number of Overseas Counterparts Led to the Imposition of Administrative Sanctions Against Several Individuals and Companies for Market Manipulation and Insider Trading Violations
  Decision No 18486 of 6 March 2013
  Decision No 18487 of 6 March 2013
  Decision No 18771 of 22 January 2014
  Decision No 19887 of 15 February 2017
  Decision No 20200 of 22 November 2017
  
• MMoU Assistance Obtained from a Number of Overseas Counterparts was Instrumental to the Imposition of Administrative Sanctions on Violators in an Insider Trading Investigation
  Decision No 19739 of 22 September 2016
• MMoU Assistance Provided by an Overseas Counterpart Was Key in an Insider Trading Investigation which Led to the Imposing of Administrative Sanctions Against a Number of Individuals and Companies for Joint Liability
  Decision No 19332 of 26 August 2015
  Decision No 19333 of 26 August 2015
  Decision No 19389 of 11 September 2015
  
• MMoU Cooperation with an Overseas Counterpart in an Insider Trading Investigation Led to the Imposition of Administrative Sanctions on a Resident of the Overseas Counterpart
  Decision No 19014 of 27 August 2014
• Information Received from an Overseas Counterpart Triggered an Administrative Insider Trading Investigation
  Decision No 18277 of 18 July 2012
• MMoU Cooperation with Three Overseas Counterparts in an Insider Trading Investigation Led to the Imposition of Administrative Sanctions on a Number of Entities Based Abroad
  Decision No 16983 of 4 August 2009
  Decision No 17169 of 10 February 2010
  Decision No 17170 of 10 February 2010
  Decision No 17171 of 10 February 2010
  Decision No 17172 of 10 February 2010
  
• Beneficial Ownership Was Established in a Market Manipulation Investigation Through MMoU Cooperation
  Decision No 17589 of 14 December 2010

Financial Services Agency/Securities and Exchange Surveillance Commission, Japan

• MMoU Cooperation with an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading by an Individual Residing Abroad
  December 2021
• MMoU Cooperation with Overseas Counterparts Was Instrumental in the Investigation that Led to a Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  December 2021
• MMoU Cooperation with an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation by Individual Investor Residing Abroad
  June 2018
• MMoU Assistance Provided by Overseas Counterparts Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading by an Individual Contractor Residing Abroad
  June 2017
• MMoU Assistance Provided by an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading
  March 2017
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading
  June 2016
• MMoU Assistance Obtained from an Overseas Counterpart led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  March 2016
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  February 2016
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading by an Individual Investor Residing Abroad
  October 2015
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading by Officer of Party in Negotiation to Conclude Contract
  June 2015
• MMoU Assistance Obtained from an Overseas counterpart Was Instrumental to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  March 2015
• MMoU Assistance Obtained from an Overseas Counterpart Was Instrumental to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  December 2014
• MMoU Assistance Obtained from an Oversea Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  February 2014
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Insider Trading
  December 2013
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Using Fraudulent Means by a company in its Securities
  November 2013
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation
  July 2013
• MMoU Assistance Obtained from an Overseas Counterpart Led to the Recommendation for Administrative Monetary Penalty Payment Order for Market Manipulation of the Shares of a Company
  December 2012