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U.S. Publications 

Non-wall crossed conversation results in UK fine on US-based fund for insider dealing 

03 February 2012

The UK Financial Services Authority has imposed a significant fine on a US-based hedge fund for market abuse insider dealing, notwithstanding that the fund manager received the information in question on the express understanding that he was not being made an insider or “wall-crossed”.

The FSA’s decision is likely to have a number of important practical implications not only for investors and fund managers but also banks, issuers, brokers, compliance teams and analysts around the world. The decision also demonstrates that the FSA may impose civil liability for overseas conduct, and highlights that the UK market abuse regime differs substantially from the equivalent US regime.

For more information please contact: Casper Lawson, (+1) 212 903 9125, Caird Forbes-Cockell,(+1) 212 903 9040, Andrew Webb, (+1) 212 903 9435, Daniel Law, (+1) 212 903 9429 or your usual Linklaters contact.

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