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Financial crime

STOR (Suspicious Transaction and Order Report)

A Suspicious Transaction and Order Report (STOR) is a report a firm must submit to the FCA under the UK Market Abuse Regulation when it has reasonable suspicion that a transaction or order may involve insider dealing or market manipulation. It is the market-abuse equivalent of an AML Suspicious Activity Report.

A Suspicious Transaction and Order Report (STOR) is a report that a firm must submit to the FCA under the UK Market Abuse Regulation (MAR) when it has a reasonable suspicion that a transaction or order, whether executed or not, may constitute insider dealing or market manipulation. The STOR regime is the market-abuse equivalent of the anti-money laundering Suspicious Activity Report: it places an active detection-and-reporting obligation on firms, not just a duty to refrain from market abuse themselves.

Why STORs matter

MAR requires firms that arrange or execute transactions to establish and maintain effective arrangements, systems and procedures to detect and report suspicious orders and transactions. A STOR must be made without delay once a reasonable suspicion is formed. Failing to detect or report suspicious activity is itself a compliance failing that the FCA can act on, independently of any underlying market abuse.

Firms must also keep records of the analysis behind a decision not to submit a STOR, so the judgement can be evidenced.

Who it applies to

Investment firms, brokers, trading venues and any firm professionally arranging or executing transactions in financial instruments.

MAR and SAR.

Frequently asked questions

What is a STOR?
A STOR, or Suspicious Transaction and Order Report, is a report a firm must submit to the FCA under the UK Market Abuse Regulation when it has reasonable suspicion that a transaction or order could involve insider dealing or market manipulation. It is the market-abuse counterpart to a Suspicious Activity Report in the anti-money laundering regime.
Who must submit STORs?
Firms that arrange or execute transactions in financial instruments, including investment firms, brokers and trading venues, must have arrangements to detect and report suspicious transactions and orders. Under the UK Market Abuse Regulation, the obligation is to report a reasonable suspicion to the FCA without delay, and failure to do so can itself be a breach of MAR.

Reviewed by Margaret Hassett

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