Current Insider Trading Regulatory and Enforcement Environments: Appropriate Policies and Procedures (Part Two of Two)

One issue that is always a priority for the SEC is insider trading. Thus, Seward & Kissel's Seventh Annual Private Funds Forum included a panel that examined the current regulatory and enforcement environment around insider trading. The discussion was moderated by Seward & Kissel partner Patricia A. Poglinco and featured partners Paul M. Miller and Jack Yoskowitz, as well as counsel Philip Moustakis. This second article in a two-part series presents the panelists’ observations on recent examination focus on insider trading policies and procedures; the development of appropriate policies and procedures for handling material nonpublic information; trade surveillance and monitoring; use of alternative data; and the prospects for enforcement activity under Chair Gary Gensler. The first article analyzed the panelists’ insights on the various ways that the SEC obtains information about potential insider trading; SEC requests for information about trading issues; and recent enforcement activity and litigation. See “How Fund Managers Can Handle Insider Trading Risks After U.S. v. Chow” (Jun. 24, 2021).

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