Abstract
PurposeThis paper aims to remind investment firms of the importance of policies, procedures, and supervisory controls to detect the misuse of material, non‐public information.Design/methodology/approachSummarizes a recent increase in regulatory concern over insider trading and suggests that firms review their “information wall” procedures.FindingsAt a minimum, a firm's information wall procedures should include the following elements: surveillance of employee trading; supervision of interdepartmental communications, including “walling off” procedures and procedures for “wall crossings”; a review of proprietary training when the firm is in possession of material, non‐public information; employee training and education, and documentation.Originality/valueReviews the key elements of an investment firm's insider trading policies.
Published Version
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