Sweden – FI Fine Late Shareholding Disclosure

Sweden – FI Fine Late Shareholding Disclosure

On 28 January 2020, SWE FI fined Vulcan for late disclosure of holdings.

  • Vulcan Value Partners LLC fined penalty of SEK 340,000, for late reporting of holdings.
  • That holding of shares in the company Concentric AB, had fallen below a flagging limit.

Key Facts

  • On 26 September 2017, Vulcan reduced shareholding in Concentric, to under 5% of shares.
  • Therefore had to register as change in ownership with SWE FI, no later than 29 September 2017.
  • Initial shareholding disclosure was received by SWE FI on 3 November 2017, and corrected on 6 November 2017.
  • Obligation considered complete on 6 November 2017 when correct disclosure received.


  • Disclosure 25 days late, applying standard model, penalty of SEK 680,000 estimated.
  • However, given the long processing time in the case and the company's fundamental right to trial within a reasonable time, SWE FI set the penalty at SEK 340,000.
  • The penalty fee will be invoiced on expiry of the statutory time limit for appeal.