On November 22, the EU Committee of European Securities Regulators (CESR) published a report setting out the differing sanctions available in EU Member States under the EU Market Abuse Directive (MAD). CESR’s report is part of an ongoing process to achieve uniformity across the EU.

MAD requires Member States to have "effective, proportionate and dissuasive" measures and sanctions in place to be imposed against persons failing to comply with the provisions of the directive. MAD allows Member States to determine the size of fines and the types of administrative measures that their regulatory authorities may take and also left the application of criminal sanctions in market abuse cases at the discretion of Member States.

The report highlighted variations in the ability to administer fines, force imprisonment, withdraw licenses, disgorge profits, and require settlements.