Market Abuse Risk / Controls Assessments

Market abuse enforcement cases continue to be a key area of focus for the FCA and the SEC, including both insider trading and market manipulation cases.

However, a more recent trend, since at least 2014, is for the FCA to conduct market abuse controls assessments on firms – in particular alternative investment managers – and to take action against firms where deficiencies are identified, even in the absence of any suspected market abuse.

It is critical therefore that firms proactively ensure that their market abuse controls are fit for purpose, and effective in mitigating the risk of market abuse. Importantly, firms should also ensure that these are in line with the FCA’s expectations because, despite the lack of detailed rules in this area, the FCA has shown that it has clear expectations on what is required and will act against any perceived shortcomings.

This imperative has only increased as a result of the introduction of the EU Market Abuse Regulation in 2016, which has further raised the bar in this area. The FCA has recently indicated that the honeymoon period for these new requirements is over and firm should by now be fully compliant.

Greyline’s U.K. division has experience in conducting such reviews for large and mid-size alternative investment managers, including a number of the top firms in the U.K. This includes being part of the FCA visit teams conducting these assessments starting in 2014/2015, leading a number of assessments and more recently conducting similar assessments in private practice.

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Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
Greyline is pleased to announce that we are the recipient of the 2021 HFM U.S. Service Award in the Best Technology Firm – Newcomer category.