ESMA yesterday issued a Questions and Answers document on the Market Abuse Regulation (MAR), which is effective from the 3rd July 2016. It can be found here. There is only one question and answer, which reminds market participants that the monitoring obligation found in Article 16(2) of MAR apply to a wide variety of firms, including “Persons Professionally Arranging or Executing Transactions” (PPAETS), even if they are not financial companies under MiFID and not directly supervised by financial regulators.
The “PPAET” is widely defined, more so than the “PPAT” under REMIT. This document should serve as a reminder to energy and commodity market participants, to ensure that they have effective monitoring in place for the start of MAR.