Almost everyone trained on the market abuse regime was trained on it from the execution side, where abuse arrives from a client, passes through the systems of the firm, and the job is to spot it and report it. Portfolio management inverts that completely. No client sends the order. Once the mandate is signed the investment decision sits with the portfolio manager, so the risk does not arrive from outside the firm at all. It sits inside the decision itself, and the person under scrutiny is a colleague.

This seminar is built for that reality. It works through seven real enforcement decisions, taken from the published final notices, criminal judgments and regulatory decisions themselves, and turns each one into a control a firm can actually operate.

What you will learn

• Tell the three offences apart. Insider dealing, unlawful disclosure and market manipulation fail in different ways and are defended in different ways.
• Apply the desk test in real time. Precise, not public, price sensitive, applied while a conversation is still running rather than an hour later.
• Run a compliant wall crossing. The order the steps come in, what signing does, what refusing does, and the exact moment dealing must stop.
• Read an order book for manipulation. What separates an order meant to trade from one placed only to be seen.
• Test whether surveillance actually fits the business, rather than whether the firm merely owns a system.
• Make personal account rules real, with pre-approval, verification against statements and restricted lists.

The seven enforcement cases

• Greenlight Capital and Einhorn. An investor who refused to be wall crossed, took the call anyway, and sold within minutes. Four separate people could have stopped it.
• BlackRock and Lyttleton. An offshore company opened a full year before the trades, and a custodial sentence at the end of it.
• The Korfuzi conspiracy. A family operation run from one flat, defeated by the one thing that was never disguised.
• Abbattista. Thousands of visible, entirely lawful orders that were never intended to trade.
• EcoR1 Capital and Innate Pharma. Genuine orders, every one of them executed, timed to bend a reference price. Under appeal.
• Bourse Direct. A surveillance system that produced thousands of alerts a year and was structurally incapable of catching the client it had already flagged.
• Makor Securities Paris. Three conditions promised to the regulator, and three conditions inverted. Under appeal.

Who should attend

Portfolio managers and investment managers with discretionary mandates, heads of compliance, compliance officers and MLROs in asset management firms, risk and internal audit staff covering investment functions, and directors of licensed firms who carry personal responsibility for control failures. It suits holders of the CySEC Advanced and Basic certifications, and anyone maintaining continuing professional development in a regulated investment firm.

Regulatory frameworks covered

Regulation (EU) No 596/2014 on market abuse, in particular Article 8 on insider dealing, Article 10 on unlawful disclosure and Article 12 on market manipulation. Enforcement decisions are drawn from the United Kingdom and France, and the control expectations they set out apply across the European Union.

CPD hours and format

Five CPD units, structured as five hours of learning. Twelve video lessons totalling 150 minutes, a written reading lesson of 130 minutes that is yours to keep, and a 20 minute assessment. The assessment is ten multiple choice questions with a pass mark of 70 per cent, and passing it produces the certificate.

How this differs from our introductory market abuse course

This is not an introduction. If you want the regime explained from the beginning, with the general concepts and supervisory statistics, start with our MAR fundamentals course, which covers market abuse generally and from the execution side. This seminar assumes that grounding and takes a different angle entirely, namely what changes when the investment decision, and therefore the risk, sits inside the firm.

If your responsibilities extend across the wider obligations of an asset management firm, our course on the functional responsibilities of an asset management firm under MiFID II sets out how the compliance, risk and portfolio management functions fit together. For the same case led approach applied to financial crime, see learning from AML enforcement failures.