UT (Tax & Chancery) UT-2022-000134 UT-2022-000135 UT-2022-000137 - [2025] UKUT 00214 (TCC)

the conduct of the individual in bringing (or failing to bring) quickly, effectively and completely the market abuse to the Authority’s attention (or the attention of other regulatory authorities, where relevant);

the degree of cooperation the individual showed during the investigation of the market abuse by the Authority, or any other regulatory authority allowed to share information with the Authority;

whether the individual assists the Authority in action taken against other individuals for market abuse and/or in criminal proceedings;

whether the individual has arranged his resources in such a way as to allow or avoid disgorgement and/or payment of a financial penalty;

whether the individual had previously been told about the Authority’s concerns in relation to the issue, either by means of a private warning or in supervisory correspondence;

the previous disciplinary record and general compliance history of the individual;

action taken against the individual by other domestic or international regulatory authorities that is relevant to the market abuse in question;

whether Authority guidance or other published materials had already raised relevant concerns, and the nature and accessibility of such materials; and

whether the individual agreed to undertake training subsequent to the market abuse.