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Market Abuse Policy Template
Market abuse isn't just a compliance risk — it's a criminal one. Under UK MAR Article 16, every FCA-authorised firm must maintain effective arrangements, systems, and procedures to prevent and detect market abuse, and submit STORs without delay when reasonable grounds to suspect it arises. The penalties for failure are severe: unlimited fines, permanent prohibition from regulated activities, and criminal prosecution under the Criminal Justice Act 1993. Zero tolerance requires zero gaps.
What's included:
Full UK MAR regulatory framework: Articles 7/8/10/12/15/16/18/19/23, MAR Sourcebook, Criminal Justice Act 1993, FSMA 2000, SYSC 4/6/10, and SM&CR conduct requirements
Market manipulation taxonomy: transaction-based, order-based, dissemination-based, and benchmark manipulation — with real-world scenarios including wash trading, ramping, and information manipulation
Article 18 insider list requirements: mandatory fields, 5-year retention, and monthly compliance review — with three-tier market-sensitive information classification and information barrier establishment procedures
Personal account dealing restrictions: pre-clearance procedure, 30-day minimum holding period, closed period restrictions, and PDMR Article 19 transaction reporting with €5,000 notification threshold
Transaction monitoring and communications surveillance: real-time and retrospective alert systems, email/telephone/instant messaging/mobile coverage, and 7-year retention standard
STOR submission procedure: one-working-day deadline and Article 23 tipping-off prohibition — with three-level alert escalation at 24/48/72-hour investigation timeframes
Ready-to-use appendices: market abuse risk assessment, Suspicious Transaction Report, personal account dealing pre-clearance form, information barrier breach investigation form, and product risk assessment matrix with 10-indicator RAG framework
+ much more
Who is this for?
Compliance Officers, SMF16 holders, investment managers, portfolio managers, and Boards at FCA-authorised wealth management and investment firms who need a complete, board-approved UK MAR-compliant Market Abuse framework with robust surveillance, reporting, and governance controls.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
Market abuse isn't just a compliance risk — it's a criminal one. Under UK MAR Article 16, every FCA-authorised firm must maintain effective arrangements, systems, and procedures to prevent and detect market abuse, and submit STORs without delay when reasonable grounds to suspect it arises. The penalties for failure are severe: unlimited fines, permanent prohibition from regulated activities, and criminal prosecution under the Criminal Justice Act 1993. Zero tolerance requires zero gaps.
What's included:
Full UK MAR regulatory framework: Articles 7/8/10/12/15/16/18/19/23, MAR Sourcebook, Criminal Justice Act 1993, FSMA 2000, SYSC 4/6/10, and SM&CR conduct requirements
Market manipulation taxonomy: transaction-based, order-based, dissemination-based, and benchmark manipulation — with real-world scenarios including wash trading, ramping, and information manipulation
Article 18 insider list requirements: mandatory fields, 5-year retention, and monthly compliance review — with three-tier market-sensitive information classification and information barrier establishment procedures
Personal account dealing restrictions: pre-clearance procedure, 30-day minimum holding period, closed period restrictions, and PDMR Article 19 transaction reporting with €5,000 notification threshold
Transaction monitoring and communications surveillance: real-time and retrospective alert systems, email/telephone/instant messaging/mobile coverage, and 7-year retention standard
STOR submission procedure: one-working-day deadline and Article 23 tipping-off prohibition — with three-level alert escalation at 24/48/72-hour investigation timeframes
Ready-to-use appendices: market abuse risk assessment, Suspicious Transaction Report, personal account dealing pre-clearance form, information barrier breach investigation form, and product risk assessment matrix with 10-indicator RAG framework
+ much more
Who is this for?
Compliance Officers, SMF16 holders, investment managers, portfolio managers, and Boards at FCA-authorised wealth management and investment firms who need a complete, board-approved UK MAR-compliant Market Abuse framework with robust surveillance, reporting, and governance controls.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.

