If someone is trading on inside information, there’s a decent chance it’s not the only thing they’re up to. It’s often a red flag for broader misconduct – money laundering, bribery, fraud. And these behaviours can move through your systems without raising the usual alarms if you’re not looking for them in the right way.
You might be monitoring for large or unusual transactions, but insider trading can fly under the radar. Trades might be small, spread across multiple accounts, or routed through less obvious counterparties. But put under the microscope, they might follow odd timing patterns – like buying right before a stock jumps or selling just before it drops. That’s where behavioural analytics and stronger collaboration with your market abuse or surveillance teams come in.
You should be thinking about how your AML controls overlap with market abuse risks. If you’ve got a client trading frequently and profitably around news events, does your system flag it? Does your team know what a suspicious trading pattern looks like? Is there an escalation route if someone in surveillance sees something dodgy?
It also matters in onboarding. If you’re bringing on a high-net-worth individual who works in or close to a listed company, ask the right questions. What’s their relationship to that company? Do they have inside knowledge? Have they been involved in regulatory investigations in the past? You’re not just ticking a Know Your Customer (KYC) box but building a picture of risk. And insider trading is a part of that picture.
Finally, think about your internal culture. Insider trading cases don’t always come from external clients. They come from within. Do your own people understand the risks? Are there controls to monitor staff trading activity? Do they know how to report if they spot something off? Your first line of defence is always your people. But only if they know what to watch for.