Mitigating Insider Trading Risks: Expert Networks, Political Intelligence, Meetings With Management, Data Rooms, Information Barriers and Office Sharing (Part Two of Two)

A recent ACA Compliance Group (ACA) program, featuring Joel Stocksdale and Erika Chua, ACA senior principal consultant and principal consultant, respectively, addressed common insider trading risks and the controls that fund managers can implement to mitigate those risks. This article, the second in a two-part series, highlights specific controls related to common sources of insider trading risk, including expert networks, political intelligence, meetings with management, data rooms, information barriers and office sharing. The first article covered the portions of the program that addressed the relevant laws and regulations; internal controls applicable to all advisers; restricted lists; confidentiality agreements; personal trading; testing; and training. For additional commentary from ACA, see our two-part series on maintaining books and records: “Compliance With Applicable Regulations” (Nov. 2, 2017); and “Document Retention and SEC Expectations” (Nov. 9, 2017).

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