Insider trading surveillance
Insider trading surveillance in the Trade and Geopolitical Risk sector sits at an uncomfortable intersection: material non-public information about sanctions designations, export control actions, and cross-border enforcement decisions moves through firms before it becomes public record. The U.S. Securities and Exchange Commission and the Commodity Futures Trading Commission have each issued guidance tying geopolitically sensitive information flows to existing market manipulation and insider trading frameworks, and the European Securities and Markets Authority has pushed member-state enforcers to treat trade policy intelligence as a potential source of market abuse under MAR Article 7. Compliance teams are now auditing information barriers between government affairs functions and trading desks, specifically because regulators have made clear that the source of material information does not need to be a company insider to trigger liability.
Watch
- MAR Article 7 scope creep into trade policy intelligence from government affairs teams
- CFTC guidance on material non-public information sourced from geopolitical channels
- SEC enforcement pattern: information barrier failures tied to sanctions pre-announcement trading
- ESMA Q&A updates on what constitutes 'inside information' for commodity-linked instruments
- Export control pre-decisional leakage as a trigger for parallel SEC and DOJ referrals
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to insider trading surveillance will appear here as they are published.