Sweden – FI Fine Late Shareholding Disclosure Reporting

Sweden – FI Fine Late Shareholding Disclosure Reporting

On 11 August 2021, SWE FI fined TVL Gold 1 for late shareholding disclosure reporting.

  • SWE FI fined TVL Gold 1 LLC for late shareholding disclosure in Endomines AB.


  • TVL Gold 1 LLC (the company) is related to AA, a person in a leading position in Endomines AB in July 2020, and on 30 July 2020, the company announced that it had completed numerous transactions in Endomines, totaling 618,673 shares.
  • On 27 October 2020, SWE FI raised the question of whether the company had breached its obligation pursuant to article 19 of the EU market abuse regulation.
  • The company was notified of the suspicion on the same day, it stated that the sale was carried out by the bank with which the shares in question were registered and kept.
  • The company assumed that the bank would carry out all necessary notifications.
  • The assumption was incorrect, as soon as the mistake was discovered on 30 July 2020 the transactions were reported to SWE FI, the delays were due to a misunderstanding.
  • There was no intention to mislead the market and the mistake will not be repeated.


  • TVL Gold 1 LLC fined SEK 950,000 for failure to report transactions in prescribed time.