Activity · Securities trading desks

Market Abuse — Securities TradingDraft

Assessment of insider dealing and market manipulation risks across equity and fixed income desks.

Draft — awaiting 4-eye validation

This assessment was modified after its last validation. Changes below are compared with the validated baseline. Authored by Marc Lefèvre. Only a different reviewer can validate or reject.

UpdatedRiskInsider dealing by staffMarc Lefèvre · 29 Sept 2026, 16:42
Likelihood
Before: Very unlikely
After: Unlikely
Rating
Before: Medium
After: High

You authored changes in this draft. Another reviewer must validate them (4-eye check).

R-2001

Insider dealing by staff

Modified

Employees with access to inside information trade, or tip others to trade, before public disclosure.

Market ConductMarket AbuseMAR Art. 14MAR Art. 18

Impact: Very severe
Likelihood: Unlikely
Inherent: High
Residual: Medium

Mitigating controls (1) · Owner: Sofia Martins

C-5005Insider list and watch list maintenance
Preventive · Manual · Ongoing
Weight 1Partially effective

R-2002

Market manipulation through order flow

Spoofing, layering or wash trades are executed through firm or client order flow without detection.

Market ConductMarket AbuseMAR Art. 12MAR Art. 16

Impact: Severe
Likelihood: Unlikely
Inherent: Medium
Residual: Low

Mitigating controls (1) · Owner: Sofia Martins

C-5006Trade surveillance alert review
Detective · Semi automated · Daily
Weight 1Effective

R-2003

Unrecorded client communications

Order-related communications take place over unapproved or unrecorded channels.

Market ConductRecord KeepingMiFID II Art. 16(7)

Impact: Moderate
Likelihood: Likely
Inherent: Medium
Residual: —

Mitigating controls (1) · Owner: Sofia Martins

C-5007Quarterly recorded-line sampling
Detective · Manual · Quarterly · 15 Jan, 15 Apr, 15 Jul, 15 Oct
Weight 1Not rated