Season 10, Episode 6: Insider dealing lists: lessons from a conviction

In Episode 6 of Season 10, Helen Parry, senior Regulatory Intelligence Expert speaks to Rachel Wolcott, senior editor about the UK Financial Conduct Authority's (FCA) recent success in securing an insider dealing conviction. The FCA's enforcement co-heads—Therese Chambers and Steve Smart --have used this conviction to reassert the regulator's intention to get tough on insider dealing. A previous enforcement head said the same thing in 2015. Rachel asks Helen what is different this time.

Helen explains some of the issues the recent conviction raises about insider dealing list management
and the loopholes those convicted of market abuse or insider dealing think they are taking advantage of
when trading illegally. For example, Mohammed Zina, whom the FCA convicted this month, argued he
was not insider dealing, because he was not on an insider list. That argument did not stand up in court
and Helen offers listeners examples of other similar failed defence arguments. Helen and Rachel talk
through two recent FCA Market Watch newsletters related to market abuse and insider dealing and
touch on some updates to the UK's criminal insider dealing regime.

Links
Helen on the Zina/Goldman case: COLUMN: Ex-Goldman Sachs conflicts resolution group analyst
convicted of insider dealing http://go-ri.tr.com/b4UU6K

Helen on Insider dealing and organised crime:
COLUMN: More connections emerge between criminal insider dealing cases in courts in the UK, US and
France ( January 2020) http://go-ri.tr.com/Oc83Bs

COLUMN: Insider dealing appeal throws more light on international networks of convicted day trader
http://go-ri.tr.com/Q3Sjuh

Rex vs Mohammed Zina sentencing remarks: https://www.judiciary.uk/wp-content/uploads/2024/02/R-
v-Zina.pdf

EXPLANATORY MEMORANDUM TO THE INSIDER DEALING (SECURITIES AND REGULATED MARKETS)
ORDER 2023 https://www.legislation.gov.uk/uksi/2023/582/pdfs/uksiem_20230582_en_001.pdf

Market Watch 76, flying and printing https://www.fca.org.uk/publications/newsletters/market-watch-76

Market Watch 77, insider dealing by organized criminal groups: https://www.fca.org.uk/publications/newsletters/market-watch-77

Compliance Clarified Series 9, Episode 1: UK Financial Conduct Authority's enforcement arm: "all bases
covered"or "highly unsatisfactory"?: https://podcasts.apple.com/gb/podcast/series-9-episode-1-uk-financial-conduct-authoritys/id1548510826?i=1000629486982

Contact us
Rachel.Wolcot@Thomsonreuters.com
Helen.Parry@thomsonreuters.com

More information about Thomson Reuters Regulatory Intelligence https://legal.thomsonreuters.com/en/products/regulatory-intelligence

Compliance Clarified is a podcast from Thomson Reuters Regulatory Intelligence.
Listen to wide-ranging, insightful discussions on all things compliance for financial services firms. We delve into the hot topics of the day, the challenges faced and offer up practical ideas for emerging good practice. We de-mystify regulation and explore the art, as well as the science, of the ever-expanding role of the compliance officer.  Enforcements, digital transformation, regulatory change, governance, culture, conduct risk – anything and everything impacting the compliance function is up for discussion.