On 10 December 2015, the FCA published findings of its process review, based on how a sample of investment banking firms manage the confidential and inside information they receive and generate. The key findings include:

  • firms to consider the circumstances posing heightened levels of risk for misuse of confidential and inside information, and whether these have been considered and mitigated appropriately;
  • all staff members across the three lines of defence have a role to play to ensure that the flows of confidential and inside information are adequately controlled (although the FCA noted that ultimate responsibility resides with senior management); and
  • robust systems, procedures, and infrastructure underpin the effective management of flows of confidential and inside information in firms.