Podcast
Questions and Answers
Which employees are designated as ‘higher risk staff’?
What products are designated as Relevant Financial Assets, as per the Personal Account Dealing Policy?
What are the de-minimis thresholds for cryptocurrencies and fiat currencies, above which pre-approval must be sought?
Who is required to get pre-approval for trades in relevant assets above the defined de-minimis thresholds?
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For ‘higher risk staff’, from whom should pre-approval for trades in relevant assets above the defined de-minimis thresholds be sought?
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What is the minimum holding period for assets purchased through Personal Account dealing?
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How do employees seek pre-approval for Personal Account trades?
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Which of the following groups of risks might or are most likely to crystallize from Personal Account Dealing that was not conducted within regulations or internal policy?
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Which of the following Market Conduct risks / behaviors might or are most likely to result from Personal Account Dealing that was not conducted within regulations or internal policy?
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(UK EMPLOYEES ONLY) In the UK, what are the possible or most likely punishments for Personal Account Dealing misbehaviors, such as Insider Dealing?
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(US EMPLOYEES ONLY) In the US, what are the possible or most likely punishments for Personal Account Dealing misbehaviors, such as Insider Dealing?
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Study Notes
Personal Account Dealing Knowledge Test
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B2C2 employees using confidential information: B2C2 employees cannot use confidential client information for personal account trades. Approval is required if using client information.
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Higher risk staff: EXCO members, all revenue generating staff (sales, trading, quant devs), B2C2 Exco members, and B2C2 legal entity directors are designated higher risk.
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Relevant Financial Assets: Crypto and fiat currencies/deposits/debt or equity securities and related products issued by companies that are clients, counterparties, investors, vendors, or suppliers to B2C2 are considered relevant.
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De-minimis thresholds: USD 5,000 for crypto and USD 50,000 for fiat currencies require pre-approval.
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Pre-approval requirements: Employees designated as "higher risk" need pre-approval for trades above de minimis thresholds.
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Non-higher risk staff: Non-higher risk staff require pre-approval from their line manager, if not complying, compliance as well.
Pre-approval Procedures
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Higher-risk staff pre-approval: Required for trades above de-minimis thresholds. Pre-approval required from: Finance, Line Manager, HR, Head of Risk, B2C2 Limited Functional or Regional Head.
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Approval validity: Valid for one day, 36 hours, or 72 hours (there are no time limits).
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Minimum holding periods: No minimum holding period for assets purchased through Personal Account dealing.
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Close family members: Close family members of higher-risk staff, or B2C2 Employees are not subject to the Personal Account Dealing policy.
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Employee access: B2C2 employees can not access close family members’ accounts for their Personal Account trading, only with Compliance approval.
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Pre-approval methods: Employees seek pre-approval through verbal agreement from line manager or using the slack PAD workflow, or from compliance
Risk and Policy
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Personal Account risks: Market Abuse, Conflicts, Money Laundering, Terrorist financing, Proliferation financing, GDPR, Privacy, Anti-Bribery and Corruption, and Financial Crime
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Market misconduct: Marking the Close, Layering, Dissemination, Front Running, and Spoofing to execute transactions using inside information.
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UK penalties for Insider Dealing: Possible penalties include wearing a tag, community service, unlimited fines, injunctions, prohibition, and custodial sentences. (up to 10 yrs), for UK employees.
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US penalties for Insider Dealing: Penalties may include prison sentences (up to 20 years), fines up to $20 million, prohibition on further investment, forced liquidation of assets, and fines up to 3 times the profit gained/loss avoided. (for US employees)
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Client order/large order: If aware of a large client order, inform sales to advise on trading intentions.
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Inside information: Trading based on inside information is not allowed.
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Crypto news/situations: No trade restrictions if news is in the public domain, otherwise restriction for inside information.
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Significant situation: If you feel you may be using inside information, do not trade.
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Definition of material non-public information: Non-public information that is important to investor decisions and is subject to regulations.
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Description
This quiz assesses your knowledge of personal account dealing regulations for B2C2 employees. It covers confidentiality protocols, risk designations, relevant financial assets, and pre-approval requirements. Ensure you understand the rules to navigate personal trading effectively.
