Personal Account Dealing Knowledge Test

Study Notes

Personal Account Dealing Knowledge Test

B2C2 Employee Trading: B2C2 employees cannot use confidential client information for personal account trades unless explicit approval is sought and received.
Higher Risk Staff: EXCO members, revenue-generating staff (sales, trading, quant devs), and B2C2 Exco/legal entity directors are designated as higher risk staff.
Relevant Financial Assets: Crypto and fiat currencies, debt/equity securities issued by companies related to B2C2 are relevant financial assets.
De-minimis Thresholds: Pre-approval is required for crypto trades above USD 5,000 and fiat currencies above USD 50,000.
Pre-Approval Requirements: Employees designated as higher risk staff require pre-approval for relevant asset trades above the thresholds. Non-higher risk employees require pre-approval only from their line manager, or in addition, from Compliance.

Additional Notes (Pages 2-4)

Approval Validity: Pre-approvals are valid for one day.
Minimum Holding Period: No minimum holding period is required for assets purchased through personal account dealings.
Close Family Members: Close family members of higher risk staff are subject to B2C2 Personal Account Dealing policy.
Personal Account Dealing for Family: Non-higher risk staff employees cannot use close family members' accounts for personal account dealing unless with Compliance approval.
Pre-Approval Methods: Pre-approval for personal account trades can be obtained by verbal agreement with a line manager or using the Slack PAD workflow.
Personal Account Dealing Risks: Possible risks to avoid in personal account dealing include market abuse, conflicts, money laundering, terrorist financing, GDPR violations, privacy breaches, anti-bribery breaches, and financial crimes.
Inside Information: Using inside information for personal account dealings is not permissible in the UK. This is punishable.
UK Punishments for Misconduct: Misconduct can result in community service, unlimited fines, injunctions, prohibitions on firms/persons, or custodial sentences up to 10 years.
US Punishments for Misconduct: Potential punishments in the U.S. include prison sentences up to 20 years, fines up to $20 million, prohibition of further investments, and/or forced liquidation of investments.
Client Order Awareness: If a large client order is noted in a stock already held in a personal account, employees should ask sales to contact the client and ascertain their trading intentions. No action or a trade to protect position are not appropriate.
News and Restricted Assets: Employees must follow the Personal Account Dealing Policy, even for news or significant events regarding specific crypto coins. Restrictions may exist for insider information. In general, inside information in the public domain does not qualify as insider information.