The Norwegian Financial Supervisory Authority has decided to confiscate NOK 276,900 in gains from Songa Capital AS after finding a breach of the EU Market Abuse Regulation prohibition on insider dealing, based on Songa withdrawing a BORR Drilling buy order immediately after receiving inside information about an impending block sale. The case relates to a block sale of about 7.6 million BORR shares sold by Schlumberger Oilfield Holdings through Pareto Securities, following a market sounding process and at a discount of 5.5 percent to the Oslo close and 5 percent to the New York Stock Exchange close, with observed next-day price declines of 4.9 percent and 4.2 percent respectively. Finanstilsynet concluded that Songa became an insider when it accepted a market sounding script stating that the information was inside information and that orders must not be placed, amended, or withdrawn, and then agreed during a phone call to stop an existing buy order. It treated the withdrawal as insider dealing under Market Abuse Regulation Article 8 and Article 14(a) and ordered administrative disgorgement under the Norwegian Securities Trading Act, noting that this measure is not an administrative sanction and does not require proof of fault. Finanstilsynet calculated the gain by assuming the remaining 84,423 shares in the stopped order would otherwise have been executed on the New York Stock Exchange on 11 March 2024 and comparing the New York Stock Exchange volume-weighted average price of NOK 69.88 with the block sale price of NOK 66.60, producing a per-share difference of NOK 3.28 and a total of about NOK 276,900. The decision set 15 January 2025 as the deadline for Songa to confirm acceptance, and it referenced the statutory option to bring court proceedings within three months after expiry of the acceptance deadline if the decision is not accepted.