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Regulatory Sanctions

An International Comparison of Insider Trading Enforcement

March 13, 2017

[Photo:  From, 'How the Feds Pulled Off the Biggest Insider-Trading Investigation in U.S. History' - 6/1/16]


Lev Bromberg, George Gilligan, and Ian Ramsay recently published an article, ‘The Extent and Intensity of Insider Trading Enforcement – an International Comparison’, which now appears on the web site of NYU Law’s Program on Corporate Compliance and Enforcement.


The article presents the results of a detailed comparative empirical study of sanctions imposed for insider trading in Australia, Canada, Hong Kong, Singapore, the U.K., and the U.S. over a 7-year period to 2015.


Among the findings:


  • the most severe sanctions imposed for insider trading were in Australia, followed by Hong Kong, while the least severe sanctions were imposed in Singapore.


  • the frequency of sanctions in the U.S. was substantially higher than in the other jurisdictions, yet, the severity of typical sanctions in the U.S. was relatively low.


  • the U.S., which had the highest number of defendants, also had the widest range of sanctions imposed for insider trading.


  • most U.S. insider trading cases usually feature a high proportion of monetary sanctions; this can often be attributed to the SEC’s practice of issuing a penalty that approximates the amount of illicit profit – i.e., disgorgement.


  • Insider cases in the U.S. are much more complex than elsewhere because many defendants faced both criminal and civil actions - brought by the Justice Department and the SEC, respectively – for the same ‘offense’.