On 14 January 2025, DSI imposed an educational measure on a DSI certified investment specialist. The decision followed a transaction involving a suspected case of market manipulation. According to DSI, the professional’s actions were not in line with the DSI Code of Conduct.

What happened?

DSI’s investigation revealed that the certified professional received a client order to purchase shares, with a comment suggesting an anticipated price increase. The order was passed on to another institution responsible for execution. However, a staff member at that institution informed the professional that the order was refused based on advice from their compliance department, due to concerns over potential market manipulation.

Despite this refusal, the certified professional went on to execute the order independently using the trading system of their own employer.

Why does this breach the Code of Conduct?

DSI considers that the combination of the client’s specific request and the compliance warning from the executing institution should have prompted the professional to act with greater caution. Instead of proceeding directly, they should have consulted their own compliance officer before taking further steps. By executing the order without doing so, the professional acted carelessly.

Which rules were breached?

According to DSI, the following articles of the Code of Conduct were violated:

• Article 7.1.2 and 7.1.3 – DSI Core Principle 3: Act carefully
• Article 7.1.5 and 7.1.6 – DSI Core Principle 5: Comply with rules

What measure was taken?

When a breach of the Code of Conduct is identified, DSI can impose sanctions. This may involve submitting the case to the DSI Ethics Committee or offering a settlement. In this case, DSI opted for a settlement involving a mandatory training programme. In determining this educational measure, DSI also took into account the employment-related consequences the professional had already faced as a result of the incident.