A former analyst at a UK-based investment management firm was recently convicted of insider dealing. This conviction highlights the FCA’s growing use of data analytics and surveillance to uncover misconduct and reinforces the regulator’s focus on market abuse and the personal accountability required of financial professionals.
In light of this conviction, we encourage firms to evaluate their compliance and surveillance programmes to ensure they meet the FCA’s standards.
Regulatory Landscape and Enforcement Trends
The FCA continues to treat market abuse, including insider dealing and the misuse of confidential information, as a significant enforcement priority. The regulator’s approach is increasingly data-driven, leveraging advanced analytics and cross-market surveillance to detect suspicious activity.
This latest conviction reflects a broader trend: regulators are not just targeting firms but also pursuing individuals who breach market conduct rules.
The Senior Managers and Certification Regime (SM&CR) has further heightened expectations around individual accountability. Senior leaders are expected to take reasonable steps to prevent misconduct and ensure their firms have effective systems and controls in place to reduce consumer harm and strengthen market integrity.
Lessons From This Case
Whilst the details of the case are specific, the broader lessons are widely applicable. Insider dealing often stems from a combination of weak controls, poor oversight, and a culture that fails to prioritise compliance. In this instance, the individual purportedly exploited access to confidential information for personal gain, highlighting the needs for firms to monitor both access and behaviour.
Key questions firms should ask themselves include:
- Are we effectively monitoring employee access to sensitive information?
- Do we have systems in place to detect unusual trading patterns?
- Is our compliance culture strong enough to deter misconduct?
The Role of Surveillance and Data Analytics
Modern compliance programmes must go beyond manual reviews and reactive investigations. Today’s regulatory expectations require proactive, technology-enabled surveillance that can identify red flags in real time.
Integrated surveillance systems that combine trade data with communications monitoring are becoming essential. These tools can detect patterns that may indicate insider dealing, such as trading ahead of market-moving announcements or unusual activity by individuals with access to confidential information.
Culture and Training as a First Line of Defense
Technology is a powerful enabler, but it’s not enough on its own. Even the most advanced surveillance tools need to be supported by a strong culture of compliance and well-informed employees.
A firm’s people and values play a critical role to prevent misconduct. Employees must understand the rules, feel empowered to speak up, and believe that ethical behaviour is expected and rewarded. Regular training, especially scenario-based exercises, can help reinforce expectations and prepare staff to recognise and respond to potential risks. Leadership must set the tone from the top, demonstrating a clear commitment to integrity and accountability.
In addition, seeking external regulatory advice can help firms stay aligned with evolving expectations. Advisory support offers an objective view of a firm’s governance, conduct, and control environment—helping to identify blind spots, benchmark practices, and prepare for regulatory engagement. Whether responding to a thematic review or strengthening SM&CR implementation, the right guidance can keep firms on track and ahead of risk.
A Wake-Up Call
The recent insider dealing conviction should serve as a warning to firms across the financial services industry. With regulatory scrutiny intensifying and enforcement actions on the rise, now is the time to evaluate your compliance framework, enhance your surveillance capabilities, and invest in a culture that prioritises integrity.
With increasing regulatory and investor expectations, working with a trusted compliance partner—one that combines advanced technology with deep regulatory expertise—can provide the clarity, confidence, and strategic support needed to stay ahead of risk.
Take the Next Steps
At ACA Group, we partner with investment firms to build and maintain effective compliance programmes that meet today’s regulatory challenges. Here’s how we support our clients:
- Market Surveillance Solutions: Our ComplianceAlpha® platform offers trade and communications surveillance, enabling firms to detect and investigate potential insider trading and other misconduct in real-time.
- eComms, Capture, Archive and Surveillance: Our integrated solution within ComplianceAlpha enables seamless digital communication capture, archiving, and surveillance across 85+ channels, like Teams, Zoom, and WhatsApp.
- Regulatory Advisory Services: Our experienced consultants provide strategic guidance on regulatory expectations, conduct risk, governance, and SM&CR implementation. We help firms prepare for regulatory engagement and strengthen their overall compliance posture.
- Conduct and Culture Assessments: Our advisory team helps assess their culture of compliance, identify areas for improvement, and implement strategies to align behaviours with regulatory expectations.
- Training: Our experts deliver tailored training programmes and provide strategic guidance to help firms meet their obligations under SM&CR and other regulatory regimes.
Get in touch to learn how ACA’s technology and advisory solutions can help your firm to detect risks earlier, meet regulatory expectations, and build a more resilient compliance programme.