A New Direction: First Central Bank Enforcement Against A Fund Under EMIR

The Central Bank of Ireland (the "Central Bank") has fined GlobalReach Multi-Strategy ICAV (the "Fund") €192,500 pursuant to the European Union (European Markets Infrastructure) Regulations 2014, as amended (the "EMIR Regulations") for a breach of Article 9 of EMIR arising from a failure by one of the Fund's sub-funds to report over 200,000 derivative trades between January 2018 and May 2020. This enforcement is the first time the Central Bank has imposed a fine against a fund and demonstrates the Central Bank's determination that funds and their boards retain effective responsibility and accountability for compliance with applicable legislation and regulatory requirements. This enforcement is also the first time that the Central Bank has taken an enforcement action under the EMIR Regulations.