COVID-19 Has Regulators Homing in on Insider Trading and Market Abuse – Is Your Surveillance Program Ready for Increased Scrutiny?

COVID-19-related market volatility and risks posed by employees working from home have financial regulators on high alert across the globe. The SEC, FCA, SFC, and FINRA in recent months have all called out their continuing focus on detecting and punishing insider trading, market abuse, code of ethics violations, and other misconduct. Download Infographic

The regulators also show no signs of slowing down in carrying out their supervisory duties – ACA noted an observed increase in exams of SEC-registered firms in recent months.

Collectively, these developments serve to remind firms that their compliance obligations remain intact despite the challenges of the current environment.

Is your surveillance program truly risk-based?

An effective surveillance program is risk-based and holistic in approach. Firms are advised to conduct a thorough review of their surveillance process from end to end to identify gaps and determine where improvements are necessary.

To help you get started, ACA’s surveillance professionals have developed a self-assessment checklist. This list is not intended to be exhaustive; ACA’s team can help analyze the results and determine the best path forward if enhancements are needed.

Download Checklist

Watch Our On Demand Webcast

Panelists Carlo di Florio, Partner and Chief Services Officer at ACA Compliance Group and former Director of the SEC’s OCIE, Dan Hawke, Partner at Arnold & Porter and former Director of the SEC’s Market Abuse Unit, Michael Lehman, Partner and market abuse specialist at ACA Compliance Group, and Flavia Lamb, Director at ACA Compliance Europe, recently discussed the regulatory notices on market abuse, why regulators are homing in on market abuse in this environment, and practical steps firms can take to strengthen their surveillance programs.

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Related Resources

• Infographic: Regulatory Notices on Market Abuse Since March 2020
• Free Until September 4: ACA's Online Insider Trading Awareness Training
• OCIE Risk Alert Highlights Private Fund Adviser Deficiencies Related to Conflicts of Interest, Fees and Expenses, and MNPI / Code of Ethics
• FCA Market Watch 63 Reminds Firms of Market Abuse and Reporting Requirements During the COVID-19 Crisis
• The Compliance Officer’s Plan for Recovery in the Next Phase of COVID-19
• Code of Ethics Concerns and Best Practices in Times of Market Volatility
• Protect Your Firm Against Insider Trading and Other Misconduct Related to COVID-19 

For More Information

For questions or to discuss how ACA can help your firm strengthen its surveillance program, increase efficiencies through technology, and ensure your regulatory obligations are met, reach out to your ACA consultant or contact us here.

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About the Author

Michael Lehman is a Partner at ACA and co-founder of Decryptex, Inc. He leads initiatives for ACA’s market abuse surveillance technology, partnering with ACA clients and consultants to develop products that match regulatory efforts in surveillance. A frequent subject matter speaker at conferences and roundtables, Michael has over 25 years of executive experience managing the delivery of investment products and services to hedge funds, advisers, asset management firms, investment banks, and brokerage firms.

Michael earned his Bachelor of Science degree in finance from the Wharton School at the University of Pennsylvania.