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Cryptoasset Market Conduct
Cryptoasset markets often operate with less structural oversight than traditional securities markets, but the underlying market conduct principles — avoiding manipulation, protecting customers,...
Electronic Trading and Algorithmic Conduct
Algorithmic trading can execute thousands of decisions per second, which means a flawed or malicious algorithm can create market impact far faster than any human trader could — and far faster than...
Benchmarks and Index Integrity
Benchmarks and indices quietly underpin enormous value — from mortgage rates to derivative contracts to fund performance — which makes any weakness in how they're constructed, submitted to, or...
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Research Integrity and Analyst Conflicts
Investment research is valuable precisely because readers trust it to be independent — but analysts sit close to commercial pressures (investment banking relationships, personal trading, issuer...
Communications with the Public and Financial Promotions
Every piece of customer-facing communication about a financial product — an advert, a social media post, a webpage — is a financial promotion, and each one needs to be fair, clear and not...
Fair Pricing and Valuation Conduct
Pricing and valuation decisions can look purely technical, but they carry real conduct risk — an excessive mark-up, a manipulated valuation input, or an unjustified pricing exception can all...
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Best Execution and Order Handling
Best execution is the obligation to take reasonable steps to get the best overall result for a customer when executing their order — not simply the best price in isolation, but the best...
Market Manipulation and Trading Red Flags
Market manipulation doesn't always involve an obvious, single fraudulent trade — it's often a pattern of otherwise-legal-looking orders and trades designed to create a false impression of supply,...
Personal Account Dealing
Personal trading by staff in a financial firm carries a distinctive risk: the same people with access to market-sensitive information, client order flow, or research views are also, in their...
Inside Information and Information Barriers
Firms that combine advisory, research and trading activities under one roof face a structural challenge: information legitimately known in one part of the business could give an unfair advantage...
Market Abuse Foundations
Market abuse rules exist to keep markets fair for everyone trading in them, whether that's a pension fund or an individual saver. Because so much market activity is legitimate and fast-moving, the...
Failure to Prevent Fraud: Organisational Response
Some legal regimes now hold organisations directly accountable if an 'associated person' commits fraud intended to benefit the organisation, unless the organisation had reasonable fraud prevention...
Books, Records and False Documentation
Accurate books and records aren't just an accounting formality — they're often the thing that either exposes or conceals bribery, fraud and other misconduct. A payment mislabelled as a 'consulting...