The FCA has successfully secured convictions in a significant case involving insider dealing and money laundering, with illicit profits exceeding £1 million. This case underscores the critical importance of robust compliance frameworks and the role of surveillance in maintaining market integrity.
Between December 2019 and March 2021, a research analyst at an asset management firm exploited confidential, price-sensitive information and used it to trade in the shares of at least 13 companies ahead of market announcements. The trades were executed through accounts held by associates, using contracts for difference (CFD) to profit from anticipated share price movements.
Despite efforts to conceal the activity, the FCA’s market monitoring systems detected suspicious trading patterns. In addition to insider dealing, the individuals were convicted of money laundering, having made 176 cash deposits totaling nearly £200,000 from unrelated criminal sources.
The convictions highlight the FCA’s commitment to identifying and prosecuting financial misconduct, and the increasing sophistication of its surveillance capabilities.
Regulatory Crackdown
The FCA’s recent convictions for insider dealing and money laundering are part of a broader trend of heightened enforcement activity in 2025. Other recent actions include:
- A £21 million fine issued to a UK-based digital bank for failures in systems and controls, underscoring the FCA’s focus on operational resilience and governance.
- A £9.2 million penalty against a major commodities exchange for breaches related to market transparency and conduct under MiFID regulations.
- Enforcement action against a CFD trading firm for transaction reporting failures, reinforcing the importance of accurate and timely reporting under Markets in Financial Instruments Regulation (MiFIR).
- The FCA’s updated Enforcement Guide, which has streamlined investigation timelines, reducing the average case duration from 42 months to under 16 months in some instances, demonstrates a more agile and assertive regulatory posture.
This trend isn’t limited to the UK. A recent $560 million market manipulation case in India shows how aggressive trading strategies can trigger sweeping regulatory action, reinforcing the global need for proactive surveillance and governance.
Our Guidance for Compliance
This case and the FCA’s broader enforcement momentum highlights the need for firms to adopt a proactive, end-to-end compliance strategy. Key areas include:
- Market Abuse Assessment: Conduct a risk-based market abuse assessment to ensure your firm meets FCA and market abuse regulation (MAR) requirements. This includes identifying where inside information may arise, assessing the adequacy of surveillance systems, and ensuring governance structures support timely detection and reporting of suspicious activity.
- Pre-Trade Controls: Establish robust research compliance frameworks, including the recording and monitoring of research calls, to prevent the misuse of material, non-public information. Make sure your compliance framework supports your firm’s structure, risk appetite, and regulatory obligations.
- Real-Time Trade Surveillance: Implement surveillance systems that can detect and escalate suspicious trading patterns in real time. With the FCA accelerating enforcement timelines, firms must be able to respond quickly and decisively, a challenge that can be met through managed service models.
- Post-Trade Transparency: Ensure accurate and timely transaction reporting under MiFID II and European Market Infrastructure Regime (EMIR). The FCA’s recent enforcement actions show that reporting failures remain a key risk area.
- Integrated Financial Crime Oversight: Align market abuse monitoring with anti-money laundering (AML) controls to detect and respond to suspicious financial activity across the trade lifecycle.
- Be Prepared for Faster Enforcement: With the FCA streamlining its enforcement processes, firms must be ready to demonstrate compliance swiftly. This means having the right systems, documentation, and governance in place.
As these recent cases show, the FCA is accelerating its enforcement efforts and raising expectations around market abuse, AML, and transaction reporting. Firms must be prepared to act swiftly, prove control, and maintain compliance across the full trade lifecycle.
ACA’s FCA Compliance Solutions
At ACA, we support firms in building and maintaining resilient compliance programs with solutions that combine cutting-edge technology with specialist support designed to protect your firm across the full trade lifecycle:
Pre-Trade: Strengthen Research Monitoring
- Automate the capture and review of research interactions with Research Compliance Solutions, our managed services solution that empowers research and compliance teams to navigate expert networks, research meetings, and third-party engagements with confidence. This is powered by Encore AI, ACA’s proprietary intelligence engine.
- Map your business to key market abuse risks with our risk assessment, aligned with FCA and MAR guidance. Identify gaps across complex areas like information barriers, private credit, and cross-asset activity, while enhancing your control and testing environment.
Trade: Detect and Investigate Market Abuse
- Automate detection of insider trading and market manipulation across asset classes with ComplianceAlpha®’s Market Abuse Surveillance Solution.
- Enhance eComms surveillance with ComplianceAlpha’s technology-driven solutions that capture, archive, and monitor electronic communications to identify potential misconduct and support regulatory compliance.
- Extend your team with ACA’s managed surveillance services to reduce false positives, uncover hidden risks, and stay ahead of regulatory expectations without overloading internal resources.
Post-Trade: Ensure Reporting Accuracy
- Strengthen your EMIR and MiFIR reporting with ACA’s Regulatory Reporting Monitoring and Assurance solution (ARRMA), which blends technology with independent human oversight to uncover hidden issues, benchmark performance, and deliver regulator-aligned diagnostics. Book a free review today.
- Extend your oversight and deliver a complete view of your trade-lifecycle with ACA’s Transaction Cost Analysis (TCA) solution, designed to help firms meet best execution obligations and gain deeper insights into trading performance.
Cross-Lifecycle: Strengthen Your Compliance Foundation
- Streamline AML operations while supporting onboarding, screening, and remediation through structured workflows, integrated technology, and expert managed services solutions.
- Engage our advisory services to assess, design, and protect your compliance framework across the trade lifecycle.
Contact us today to learn how we can help you strengthen controls, reduce risk, and gain peace of mind.