Fine‑Tuning Surveillance to Mitigate Heightened Insider Trading Risk

The dramatically expanded work-from-home environment, extreme market volatility and the rush to develop vaccines resulting from the ongoing coronavirus pandemic have increased the risk of misuse of material nonpublic information, insider trading and other market abuse. Regulators are keenly focused on that elevated risk. To help advisers mitigate that enhanced risk, a recent ACA Compliance Group (ACA) program surveyed the current regulatory, examination and enforcement landscape; addressed how advisers can ensure that their surveillance and monitoring procedures are sufficient to address the evolving environment; and discussed other recent compliance concerns. The program featured Carlo di Florio, partner and chief services officer at ACA and former director of the SEC’s Office of Compliance Inspections and Examinations; Flavia Lamb, director at ACA; Michael Lehman, partner at ACA Technology Solutions; and Daniel M. Hawke, partner at Arnold & Porter, former chief of the SEC Market Abuse Unit and Director of the SEC’s Philadelphia Regional Office. This article presents the key takeaways from the program. For more from ACA, see “ACA Briefing: Regulatory Responses to Coronavirus Pandemic and Best Practices for Business Continuity and Compliance” (Apr. 16, 2020).

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