UK FCA Insider Dealing Control

On Mar. 27, FCA proposed financial crime guide on insider trading.

  • FCA has launched consultation on change to the financial crime guide for firms.
  • Crime captures a range of offenses, including insider dealing and manipulation.
  • However, guide does not currently cover countering the risks of insider dealing.

Aims and Scope

  • Guide provides practical assistance, information for firms of all sizes on actions
    they can take to counter risk that they might be used to further financial crime.
  • Follows FCA Dir. Hoggett Nov. 2017 speech on compliance on MAR.
  • The consultation is relevant to all firms, who are subject to financial crime rules
    in SYSC 6.1.1R, and who arrange, or execute, transactions in financial markets.

Insider Dealing Section

  • Proposal is to create a new chapter on insider dealing and market manipulation.
  • Observation of good and bad market practice around the requirement to detect,
    report, counter, risk of financial crime, re insider dealing, market manipulation.
  • Miscellaneous changes as a result of recent regulatory changes, e.g. MLR 2017.
  • Propose complete renumbering to facilitate presentation in the online handbook.
  • Where a firm has had repeated concerns, about the trading behavior of a client,
    FCA will ask if it properly considered regulatory obligations, to counter the risk.

Money Laundering

  • Recognized some firms separate surveillance from financial crime/MLRO teams.
  • Where firms separate the units, ensure adequate communication between them.
  • Firms need to be aware of obligations under proceeds of crime act 2002 (POCA).
  • Including the submission of Suspicious Activity Reports (SARs), to the UK NCA.


  • Consultation open to Jun. 28, 2018, with proposed entry into force Oct. 1, 2018.