Compliance Monitor
Transactions reporting breaches cost UBS £100,000 penalty
A July 2005 suspicious transaction report to SABRE – the FSA’s database of market trades – in which UBS’s wealth management
division (UBSWM) wrongly recorded a purchase as a sale, led the firm to review its transaction reporting. It discovered that
equity transactions executed with external brokers in London reported on its independent DRS link since around October 1999
had inadvertently been hard-coded as Principal rather than Agent; UBSWM does not take proprietary positions. In further instances,
where UBSWM expected another division to report for it, the review found that transactions had either been reported incorrectly
or not at all, a situation that began in May 1999. The breaches between 1999 and 30 November 2001 were covered by SFA R5.49
and from 1 December 2001 to 6 October 2005, by SUP 17.4R (no transaction reports made) and SUP 15.6.1R (incorrect reporting).