Compliance Monitor
Litany of errors found in banks’ insider lists
The three-year imprisonment of a former UBS compliance officer who had access to confidential deal information for no authorised business purpose, and who was convicted in June of passing details on to a friend, has focussed the regulator’s mind on the state of banks’ insider lists. Denis O’Connorexplores the findings of a recent Financial Conduct Authority review of the systems and controls used by a sample of investment banks, legal advisers and other consultancies to manage access to inside information.
Denis O’Connoris a fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment. He was a member of the British Bankers’ Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group’s board and editorial panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the United Kingdom and abroad.

“Could do better!” may be a reasonable conclusion on the firms who participated in the FCA’s recent thematic review [1] on
the control of inside information. With trading on the basis of inside information first being made illegal in 1980, it is
somewhat disappointing that after almost four decades some firms do not appear to have yet adopted effective and adequate
controls to prevent the unauthorised and illegal distribution of inside information.