The total fines of over £100,000 were more than 10 times the profit made by the individuals from the unlawful trading, highlighting the punitive consequences of breaching the requirements.
The UK's insider dealing regime
The Financial Conduct Authority (FCA) oversees the UK's civil regime of insider dealing via the UK Market Abuse Regulation (UK MAR). The regime is built around the concept of ‘inside information’, being information which:
- is of a precise nature;
- relates directly or indirectly to a company or its shares; and
- is not public and would be likely to have a significant effect on price if made public.
Article 14 of UK MAR makes it unlawful to deal in shares while in possession of inside information, or to recommend or induce someone else to deal on the basis of such information. It also prohibits the unlawful disclosure of inside information.
