ACTICO Market Abuse and Insider Detection 

Trade surveillance typically covers several key areas, including employee trading activities (also via third-party bank accounts), the institution’s proprietary trading, client trading behavior, and potential fraud — such as employee-driven schemes like churning.

Rules evaluate transaction data to identify patterns that may indicate market manipulation or insider dealing. In ACTICO’s software, predefined scenarios are used to automatically monitor transaction data. When an anomaly is detected, the system immediately triggers an alert for the compliance team and initiates a workflow for further investigation.

These rules can be flexibly adapted to meet the specific regulatory requirements and business processes of each financial institution. Any changes take effect immediately — ensuring maximum agility and control in the surveillance process.

Every institution has a different risk profile. One of the key challenges in trade surveillance is defining and tailoring rules to align with the institution’s specific business model. For example, a private bank managing large portfolios for a few clients has different monitoring needs than a retail bank serving many clients. Surveillance rules must be calibrated to detect relevant true positives—such as signs of market manipulation, insider trading, or breaches of conduct—while keeping false positives to a minimum. The goal is to protect both clients and institutions without overwhelming compliance teams.

Establishing clear staff guidelines is essential for reducing the risk of insider trading and managing conflicts of interest. These guidelines set out what employees are permitted to do—and what they must avoid—when trading financial instruments.

To enforce these rules effectively, institutions typically rely on:

• Stop, watch, and restricted lists to control access to sensitive securities

• Pre-clearance processes, which allow employees to request approval before executing trades

• Ongoing monitoring to identify policy violations or suspicious activity

By implementing these measures, financial institutions foster a transparent compliance culture—protecting both employees and the organization from regulatory breaches and reputational harm.

Trade surveillance rules at most banks focus on detecting anomalies and risks across several key areas:

• Comparison of orders and transactions with market behavioor or predefined limit values

• Unusual patterns in trading activity

• Monitoring the individuals and entities involved in the transaction

• Detection of insider activity, especially involving relationship managers or known primary/secondary insiders

• Employee trading behaviour, including personal accounts and third-party bank relationships

• Cross-checking staff transactions against insider stop lists, watch lists, and restricted lists

• Fraud detection, especially misconduct by relationship managers

These focus areas help institutions identify potential risks early and ensure regulatory compliance across all trading activity.