Ireland – CB Investment Funds Breaches

Ireland – CB Investment Funds Breaches

On 30 September 2021, IRE CB fined Sarasin Funds Management €385,000.

  • IRE CB reprimanded and fined Sarasin Funds Management (Ireland) Limited €385,000 for four admitted breaches of investment funds regulations from May 25-March 2, 2018.
  • Appropriate fine of €550,000 reduced by 30% as per the settlement discount scheme.


  • Authorized UCITS fund management firm, managed by non-executive director board.
  • Some functions delegated to external providers, with ongoing monitoring; investment management services to investment manager and depository function to a depository.
  • IRE CB investigation follows August 2017 disclosure by the depository, in accordance with reporting obligation, regarding advertent breach of investment restrictions.


  • Advertent investment restriction breaches by the appointed investment manager conducting a merger of two funds managed by the firm, while acting as a delegate.
  • They also deliberately breached of obligatory investment concentration restrictions.
  • Sarasin breached UCITS regulations/merging fund prospectus investment restrictions.
  • Ineffective delegate reporting/supervision; failed exception and escalation reporting.
  • Serious weaknesses in supervision and monitoring of delegation model and merger.

Mitigating Factors

  • No previous adverse attention of supervisors or subject to other enforcement action.
  • Provided the expected level of co-operation with IRE CB during the investigation.