HKSI Licensing Examination Paper 1 (Regulation) — All Questions

An intermediary that receives 'soft dollar' benefits (such as research services) in return for directing client business must:

• a.Keep the arrangement secret
• b.Accept any benefit without restriction
• c.Use client commissions to fund the firm's holiday travel
• d.Ensure the benefits are permissible under the Code, disclose the arrangements, and ensure best execution is not compromised✓

The Code of Conduct's soft-dollar and rebate provisions permit only defined categories of goods and services, require disclosure of the arrangements to clients, and require that best execution and the client's interests are not compromised.

Fees, charges and the basis of an intermediary's remuneration for a service should be disclosed to a client:

• a.After the service has been fully performed and the charges have already been deducted from the client's account, if at all
• b.Only if the client is dissatisfied
• c.Before or at the point of providing the service, so the client can make an informed decision✓
• d.Only in the following year's tax return

General Principle 5 and the Code's disclosure provisions require fees, charges and the basis of remuneration to be disclosed before or at the point of the transaction, so clients understand the costs before committing.

If a client's investment objective changes from 'income' to 'aggressive growth', the intermediary should:

• a.Continue recommending the same income products as before, on the basis that a client's stated objectives are never relevant once the account is open
• b.Update the client's records and reassess the suitability of existing and future holdings✓
• c.Automatically liquidate the entire account
• d.Ignore the change until the next audit

Under General Principle 4 and para 5.1, client information must be kept current. A material change in the client's objectives requires the records to be updated and the suitability of recommendations reassessed.

When a client gives a clear instruction to sell a holding, the intermediary should:

• a.Seek the firm's proprietary desk's approval
• b.Wait for the price to rise first
• c.Execute the instruction promptly on the best available terms✓
• d.Substitute its own judgement and hold the position, because a representative always knows better than the client what the client should do

The Code of Conduct requires client orders to be executed promptly and on the best available terms. An intermediary must act on a client's clear instruction and must not override it with its own view.

If a recommended product's risk rating is higher than the client's assessed risk tolerance, the intermediary should:

• a.Proceed automatically, because higher risk means higher return
• b.Not proceed on a solicited basis unless it can properly justify suitability, documenting the basis✓
• c.Downgrade the product's risk rating to match the client
• d.Simply raise the client's recorded risk tolerance to the required level without discussing the change with the client at all

Under para 5.2 (suitability), a mismatch between a product's risk and the client's risk tolerance means the recommendation is presumptively unsuitable. The firm must not proceed on a solicited basis unless it can justify and document suitability; falsifying the client's profile is prohibited.

Which contact is most likely to fall within an exception to the SFO restriction on unsolicited calls?

• a.A mass automated call to every telephone number in a purchased marketing list, offering a brand-new speculative product
• b.A call to a stranger at 6 a.m.
• c.A cold call to a randomly selected member of the public
• d.A call to an existing client, during ordinary business hours, about a product of a kind the client already deals in✓

The SFO restriction on unsolicited calls (s.174) contains exceptions, including calls made in permitted circumstances to a person with whom the caller has an existing client relationship concerning products of a kind already dealt in.

A dealer mistakenly buys the wrong stock for a client. Proper conduct requires the firm to:

• a.Correct the error so the client is not disadvantaged, using a designated error account and keeping proper records✓
• b.Charge the client for the mistake
• c.Leave the wrong stock in the client's account
• d.Keep the position if it happens to become profitable, but pass any loss on the erroneous trade to the client's account

Dealing errors must be corrected so the client is not disadvantaged, processed through a designated error account, and recorded and reviewed by management. The firm must not shift its own error losses onto the client or keep the upside.

If an intermediary recommends securities in which it or a connected person has a material interest, it must:

• a.Disclose that interest to the client✓
• b.Recommend the securities only to clients who have expressly waived, in advance, their right to be told about any conflicts of interest
• c.Cancel the recommendation without explanation
• d.Say nothing, to avoid influencing the client

General Principle 6 (Conflicts of interest) requires disclosure of material interests. Where the firm or a connected person has a material interest in a recommended transaction, that interest must be disclosed and the client's interests given priority.

Marketing and advertising materials issued by an intermediary must be:

• a.Accurate, fair, clear and not misleading, presenting risks as well as benefits✓
• b.Focused only on potential gains
• c.Approved by HKEX before issue in every case
• d.Designed to emphasise headline returns while omitting any reference to risks, provided a disclaimer appears somewhere in small print

The Code of Conduct requires marketing materials to be accurate and not misleading, giving a balanced presentation that includes risks as well as potential benefits, so clients are not given a false impression.

Where a client proposes to borrow in order to invest, increasing the risk, the intermediary should:

• a.Guarantee the leveraged returns
• b.Encourage maximum leverage
• c.Ignore the borrowing in the suitability analysis
• d.Factor the additional risk of leverage into the suitability assessment and ensure the client understands it✓

Leverage magnifies both gains and losses. Under para 5.2, the additional risk from borrowing to invest must be reflected in the suitability assessment, and the client must understand the heightened risk before proceeding.

Under the Code of Conduct, the responsible officers and senior management of a firm are expected to:

• a.Concern themselves only with profitability, leaving all questions of client protection and market conduct entirely to the external auditor
• b.Establish and maintain proper standards of conduct and adherence to procedures by all staff✓
• c.Delegate all conduct responsibility to junior staff and bear none themselves
• d.Focus solely on revenue targets

General Principle 9 (Responsibility of senior management) makes senior management and responsible officers responsible for establishing and maintaining appropriate standards of conduct and for ensuring staff adhere to proper procedures.

A client instructs the firm to pay sale proceeds to a third party's bank account. The firm should:

• a.Transfer the funds to any account named in an unsigned email, since the client's verbal say-so is always sufficient authority for third-party payments
• b.Refuse all third-party payments in every case
• c.Pay without verifying the instruction
• d.Obtain proper written authority and be alert to money-laundering and fraud red flags before acting✓

Third-party payment instructions require proper verified authority and heightened alertness to fraud and money-laundering red flags, consistent with the Code of Conduct and AML requirements, before the firm acts on them.

A professional-investor classification relied on to disapply certain protections should be:

• a.Reviewed periodically to confirm the client still meets the qualifying criteria✓
• b.Extended automatically to every family member and related company of the qualifying client without any separate assessment of each of them
• c.Treated as permanent and never revisited
• d.Based only on the client's nationality

A professional-investor status that removes protections must be justified on an ongoing basis; the firm should review periodically that the client continues to meet the qualifying criteria and must assess each entity or person separately.

If a client's dealing instruction is ambiguous, the representative should:

• a.Clarify the instruction with the client before executing✓
• b.Execute whichever interpretation earns the most commission
• c.Execute both possible interpretations at once and let the client keep whichever of the two resulting positions later turns out to be profitable
• d.Guess what the client meant and proceed

Acting with due care under General Principle 2 requires clarifying an ambiguous instruction with the client before execution, rather than guessing, so the transaction reflects the client's actual intention.

Where the firm's commercial interest conflicts with a client's interest and the conflict cannot be avoided, the Code of Conduct requires the firm to:

• a.Terminate the client relationship immediately
• b.Split the difference equally between itself and the client
• c.Ensure the client is treated fairly, disclosing the conflict and giving priority to the client's interests✓
• d.Prefer its own interest

General Principle 6 (Conflicts of interest) requires conflicts to be avoided where possible and, where unavoidable, managed by fair treatment, disclosure and giving priority to the client's interests.

Under AMLO Schedule 2, when a customer is a company, the intermediary must identify any beneficial owner, meaning generally an individual who:

• a.Is a director, regardless of shareholding
• b.Holds exactly 5% of the voting shares, this being the fixed statutory figure for identifying beneficial owners of every corporate customer under the Ordinance
• c.Ultimately owns or controls more than 25% of the company, or otherwise exercises control over it✓
• d.Owns any single share in the company

AMLO Schedule 2 defines a beneficial owner of a corporate customer to include an individual who ultimately owns or controls (directly or indirectly) more than 25% of the issued share capital or voting rights, or who otherwise exercises ultimate control over the company.

Under the AMLO, customer due diligence records and transaction records must generally be kept for at least:

• a.5 years after the end of the business relationship (or after a transaction is completed)✓
• b.Six months from account opening, after which the Ordinance requires them to be securely destroyed to protect customer privacy
• c.3 months
• d.1 year

AMLO Schedule 2 requires CDD records to be kept throughout the business relationship and for at least 5 years after it ends, and transaction records for at least 5 years after the transaction is completed.

The obligation to report a suspicious transaction to the Joint Financial Intelligence Unit (JFIU):

• a.Applies to any suspicious transaction regardless of amount — there is no minimum value threshold✓
• b.Arises only once several suspicious transactions by the same customer have together exceeded one million Hong Kong dollars in a single calendar month
• c.Applies only to transactions above HK$120,000
• d.Applies only to cash transactions

The duty to report suspicion of proceeds of crime or terrorist financing (under OSCO/DTROP/UNATMO) is triggered by suspicion itself, with no de minimis threshold — any suspicious transaction must be reported to the JFIU regardless of value.

After a suspicious transaction report has been filed, an employee who tells the customer that a report has been made:

• a.Has acted properly and transparently
• b.Has breached only an internal policy
• c.Commits the criminal offence of 'tipping off'✓
• d.Must simply note it in the file

Disclosing to a person that a suspicious transaction report has been or may be made, in a way likely to prejudice an investigation, is the criminal offence of 'tipping off' under OSCO/DTROP. Staff must not warn the customer.

The three recognised stages of money laundering are:

• a.Collection, conversion and taxation
• b.Deposit, transfer and withdrawal
• c.Origination, distribution and settlement
• d.Placement, layering and integration✓

Money laundering is typically described in three stages: placement (introducing illicit funds into the financial system), layering (moving them through transactions to obscure their origin) and integration (returning them to the criminal as apparently legitimate wealth).

When a customer is identified as a politically exposed person (PEP), the AMLO requires the intermediary to:

• a.Treat the customer exactly like any ordinary retail client, since a person's political status has no bearing on money-laundering risk under the Ordinance
• b.Apply enhanced due diligence, obtain senior management approval to establish or continue the relationship, and establish the source of wealth and source of funds✓
• c.Refuse all business automatically
• d.Apply simplified due diligence

AMLO Schedule 2 requires enhanced due diligence for PEPs: obtaining senior management approval, taking reasonable measures to establish the source of wealth and funds, and conducting enhanced ongoing monitoring.

The AMLO framework is built on a 'risk-based approach', meaning an intermediary should:

• a.Assess risk only for professional investors
• b.Assess money-laundering risk once, at the very first meeting, and never revisit that assessment even as the customer's activity changes over the years
• c.Apply identical checks to every customer regardless of risk
• d.Direct more resources and scrutiny to higher-risk customers, products and situations✓

The risk-based approach in the AMLO and the SFC's AML/CFT Guideline requires firms to assess and mitigate risk proportionately, applying enhanced measures to higher-risk situations and keeping their risk assessments up to date.

Customer due diligence is not performed only at onboarding; the AMLO also requires:

• a.A single re-verification of the customer's identity precisely ten years after onboarding, with no transaction monitoring in the intervening period
• b.Continuous monitoring of the business relationship, including scrutiny of transactions to ensure they are consistent with what is known of the customer✓
• c.No further checks after onboarding
• d.Verification only when the account is closed

AMLO Schedule 2 requires ongoing monitoring of the business relationship, including reviewing transactions to ensure they are consistent with the firm's knowledge of the customer and their risk profile, and keeping CDD information current.

Sound AML controls require a firm to appoint a:

• a.Board-level committee whose sole function is to authorise, in advance, each and every individual customer transaction the firm processes during the day
• b.Full-time police liaison officer on staff
• c.Chief marketing officer to approve suspicious transaction reports
• d.Money Laundering Reporting Officer (MLRO) as the central point for receiving and evaluating internal suspicion reports✓

The SFC's AML/CFT Guideline expects firms to appoint a Money Laundering Reporting Officer (MLRO) and a Compliance Officer, giving them the authority and resources to receive internal reports, decide on external reporting to the JFIU, and oversee the AML programme.

Hong Kong's regime against terrorist financing (for example, the United Nations (Anti-Terrorism Measures) Ordinance) requires intermediaries to:

• a.Ignore sanctions lists
• b.Screen customers against terrorist and sanctions designations and freeze and report the funds of designated persons✓
• c.Screen only professional investors
• d.Report only after a year has passed

The United Nations (Anti-Terrorism Measures) Ordinance and related sanctions regimes require firms to screen against designated persons, refrain from dealing with their funds, freeze such funds, and report to the authorities.

Simplified due diligence may be appropriate under the AMLO where:

• a.The customer is a politically exposed person
• b.The customer refuses to provide any identification at all, since insisting on documents from reluctant customers is what simplified due diligence is designed to avoid
• c.The customer is lower-risk, such as certain regulated financial institutions or listed companies✓
• d.The transaction is anonymous and in cash

The AMLO permits simplified due diligence for defined lower-risk situations (for example, certain regulated financial institutions or listed companies subject to disclosure requirements), where the money-laundering risk is assessed to be low.

Onboarding a customer who is not physically present (non-face-to-face) is generally treated as:

• a.Prohibited entirely
• b.A higher-risk situation calling for additional measures to verify identity✓
• c.Lower risk requiring no checks
• d.Identical in risk to a face-to-face relationship, so the Ordinance requires no additional safeguards of any kind for remote customers

Non-face-to-face onboarding is treated as a higher-risk scenario under the SFC's AML/CFT Guideline, requiring additional identity-verification measures (such as certified documents or additional checks) to mitigate impersonation risk.

An intermediary may rely on another qualified intermediary to carry out certain CDD measures, but:

• a.It thereby transfers all legal responsibility to that other party
• b.It may do so only where the other intermediary is located outside Hong Kong and is not itself subject to any anti-money-laundering supervision
• c.It may do so only where the customer is a PEP
• d.It remains ultimately responsible for CDD compliance and must be able to obtain the underlying information without delay✓

AMLO Schedule 2 permits reliance on specified intermediaries to perform CDD, but the relying firm remains ultimately responsible for compliance and must be able to obtain the CDD information from the third party without delay.

Where a customer presents higher money-laundering risk, enhanced due diligence typically includes:

• a.Reducing the frequency of monitoring
• b.Increasing the customer's trading limits automatically, to reward them for the additional documentation the firm has requested
• c.Waiving identity verification
• d.Establishing the source of the customer's funds and, for PEPs, the source of their wealth✓

Enhanced due diligence for higher-risk customers involves additional measures such as establishing the source of funds (and, for PEPs, source of wealth), obtaining senior management approval, and conducting closer ongoing monitoring.

A customer who repeatedly deposits amounts just below a reporting threshold to avoid scrutiny is exhibiting:

• a.'Structuring' (smurfing), a classic money-laundering red flag✓
• b.A permitted tax-planning technique
• c.Normal cash-flow management
• d.Best practice in personal finance, which intermediaries are encouraged under the AMLO to suggest to customers who wish to keep their affairs private

Structuring (or 'smurfing') — breaking a large sum into smaller transactions to evade reporting thresholds or scrutiny — is a recognised money-laundering red flag that should prompt review and, where suspicion arises, a report to the JFIU.

Which of the following is a money-laundering red flag when reviewing a corporate customer?

• a.A locally incorporated company that files its annual returns on time and operates a genuine office with employees engaged in a real business
• b.An opaque ownership structure with no apparent commercial rationale and unclear beneficial ownership✓
• c.A long trading history with audited accounts
• d.A well-known listed parent company

Complex or opaque ownership structures with no clear commercial purpose, and difficulty in identifying the beneficial owner, are recognised red flags that call for enhanced scrutiny under the risk-based approach.

Under the AMLO, verification of a customer's identity should generally be completed:

• a.At the sole discretion of the customer, who may decline verification indefinitely provided they continue to trade actively through the account
• b.Before establishing the business relationship, with limited exceptions permitting completion as soon as reasonably practicable afterwards✓
• c.Only after the first year of trading
• d.Never, if the customer is introduced by a friend

AMLO Schedule 2 requires identity verification to be completed before establishing a business relationship, subject to limited exceptions allowing verification to be completed as soon as reasonably practicable where necessary not to interrupt normal business and where ML/TF risks are effectively managed.

When identity documents are provided by a non-face-to-face customer, a common safeguard is to:

• a.Accept plain uncertified photocopies without question
• b.Ask the customer to certify their own copies as true, since a customer is always the person best placed to confirm the authenticity of their own documents
• c.Obtain documents certified by a suitable person (for example, a professional or another regulated intermediary)✓
• d.Rely on the customer's verbal description of the document

For non-face-to-face customers, the SFC's AML/CFT Guideline suggests additional safeguards such as obtaining copies of identity documents certified by a suitable certifier, to mitigate the higher impersonation risk.

After making a report to the JFIU, the firm should:

• a.Immediately return the funds to the customer and close the file, so that the firm cannot be accused of continuing to hold the proceeds of any crime
• b.Delete all records of the matter
• c.Retain records of the report and supporting information, and follow any consent or 'no consent' guidance before proceeding with the transaction✓
• d.Publicise the report

After reporting, a firm should keep records of the report and supporting material and, before proceeding with a transaction linked to suspected proceeds of crime, have regard to the consent regime, since dealing with such property can otherwise expose it to liability.

The Financial Action Task Force (FATF) is:

• a.A Hong Kong court
• b.A Hong Kong government department that personally licenses each securities dealer and directly prosecutes money-laundering cases in the local courts
• c.The international standard-setter whose recommendations shape Hong Kong's AML/CFT regime✓
• d.The clearing house for HKEX trades

The FATF is the inter-governmental body that sets international anti-money-laundering and counter-terrorist-financing standards (the FATF Recommendations), which Hong Kong implements through the AMLO and related guidance.

A basic internal-control principle for a securities firm is segregation of duties, meaning:

• a.The dealing, settlement and audit of each transaction should all be performed by the same senior employee, so that accountability rests clearly with one identifiable individual
• b.One person should control a transaction from start to finish for efficiency
• c.Only directors may perform any operational task
• d.Incompatible functions (such as dealing, settlement and record-keeping) should be handled by different people to reduce fraud and error✓

Segregation of duties — separating incompatible functions such as dealing, settlement, custody and record-keeping — is a core internal control under the SFC's Management, Supervision and Internal Control Guidelines, reducing the risk of undetected fraud or error.

The SFC's Management, Supervision and Internal Control Guidelines address controls over areas such as:

• a.Exclusively the personal share portfolios of the firm's clients, and nothing about the firm's own management, supervision or operational systems
• b.Only the firm's tax affairs
• c.Management and supervision, segregation of client assets, risk management, operational controls, compliance and staff dealing✓
• d.Only the firm's marketing

The Management, Supervision and Internal Control Guidelines cover the whole control environment — management structure and supervision, segregation and safeguarding of client assets, risk management, operational and financial controls, compliance and staff dealing.

An effective compliance function within a licensed corporation should be:

• a.Staffed by the very dealing desk it is meant to monitor
• b.Adequately resourced and sufficiently independent to monitor and report on the firm's regulatory compliance✓
• c.Made directly subordinate to the head of sales, and required to obtain that person's approval before reporting any breach of the rules to senior management
• d.Abolished once the firm becomes profitable

The Internal Control Guidelines expect an adequately resourced and sufficiently independent compliance function that can monitor adherence to regulatory requirements and report directly to senior management, free from undue influence by the business lines it oversees.

Under the Securities and Futures (Keeping of Records) Rules, a licensed corporation must keep records that sufficiently explain its transactions and financial position for at least:

• a.3 months
• b.7 years✓
• c.30 days after each trade, after which the firm may lawfully discard them to reduce its data-storage costs
• d.1 year

The Securities and Futures (Keeping of Records) Rules require records that explain the firm's transactions and financial position to be kept for at least 7 years, supporting audit, supervision and reconstruction of the firm's dealings.

The Securities and Futures (Financial Resources) Rules (FRR) require a licensed corporation to:

• a.Keep exactly the same fixed amount of capital as every other firm in the market, irrespective of the type or scale of regulated activity it carries on
• b.Hold no minimum capital at all
• c.Invest all of its capital in client securities
• d.Maintain paid-up share capital and liquid capital at or above the prescribed minimum for its regulated activities, and report any shortfall to the SFC✓

The Financial Resources Rules require a licensed corporation to maintain minimum paid-up share capital and required liquid capital appropriate to its regulated activities, file financial returns, and notify the SFC of any shortfall.

If a licensed corporation's liquid capital falls below its required minimum, it must:

• a.Wait until the annual audit to disclose it
• b.Continue trading normally and simply add a footnote about the shortfall to next year's audited financial statements when they are eventually filed
• c.Notify the SFC immediately and cease business as required until the position is restored✓
• d.Borrow client money to cover the gap

Under the FRR, a firm that fails, or is likely to fail, to maintain required liquid capital must notify the SFC immediately and generally must not carry on regulated business until the shortfall is remedied. Client money may never be used to plug the gap.

A licensed corporation must generally submit to the SFC:

• a.Only a marketing brochure
• b.Audited accounts and the required financial returns within the prescribed periods✓
• c.A single set of unaudited figures prepared once, at the moment it is first licensed, and nothing further for the remaining life of the business
• d.No financial information at all

Licensed corporations must file audited financial statements and periodic financial returns (for example monthly or as prescribed) with the SFC within the required timeframes, enabling ongoing prudential supervision.

Sound operational controls expect a licensed corporation to maintain:

• a.Business continuity and contingency arrangements so that critical functions can continue after a disruption✓
• b.A policy of ceasing all client business permanently the first time any system outage or disruption occurs, however brief or minor
• c.No contingency plans, to save cost
• d.Plans that rely entirely on a single member of staff

The Internal Control Guidelines expect firms to have business continuity and contingency planning so that critical operations, client access and records can be maintained or promptly restored following disruptions.

SFC guidance on the security of internet trading expects firms to:

• a.Email each client their full login password in clear text every morning, so that customers who have forgotten their credentials can always trade without delay
• b.Treat cyber risk as purely an IT matter of no regulatory concern
• c.Implement controls such as two-factor authentication and monitoring to protect clients' internet-trading accounts✓
• d.Store client passwords in plain text for convenience

The SFC's guidelines on the management of cybersecurity risks and reducing internet-trading hacking risks expect controls such as two-factor authentication for client logins, monitoring, encryption and prompt incident response.

Under the Personal Data (Privacy) Ordinance, personal data collected from a client should be:

• a.Collected without limit and kept forever
• b.Collected for a lawful purpose, used only for that or a directly related purpose (absent consent), kept accurate and no longer than necessary, and adequately secured✓
• c.Published openly to demonstrate the firm's transparency
• d.Sold to any interested third party

The PDPO's Data Protection Principles require personal data to be collected for a lawful purpose, used only for that or a directly related purpose (unless the individual consents), kept accurate and no longer than necessary, adequately protected, and handled transparently, with a right of access and correction.

Before using a client's personal data for direct marketing, the PDPO generally requires the firm to:

• a.Inform the client and obtain the client's consent (or non-objection), and to cease such use on the client's request✓
• b.Obtain the SFC's approval
• c.Do nothing, as consent is always implied
• d.Sell the client's contact details to as many marketing partners as possible first, and only afterwards ask the client whether they might have preferred to opt out

The PDPO's direct-marketing provisions require a data user to notify the individual and obtain consent (or indication of no objection) before using personal data in direct marketing, and to cease using the data for that purpose if the individual so requests.

If a firm suffers a loss of clients' personal data, good practice and PDPO guidance is to:

• a.Conceal the breach indefinitely
• b.Take no action unless and until a client happens to notice the loss independently and personally lodges a formal written complaint about it
• c.Blame the clients for the loss
• d.Contain the breach, assess its impact, notify affected persons and the Privacy Commissioner as appropriate, and remediate✓

PDPO guidance on data breach handling recommends containing the breach, assessing the risk of harm, notifying affected data subjects and the Privacy Commissioner where appropriate, and taking remedial and preventive steps.

Client securities received by a firm should be:

• a.Held in safe custody and segregated from the firm's own assets, in accordance with the Client Securities Rules✓
• b.Registered in the dealer's own personal name
• c.Lent out to other clients of the firm at interest whenever the firm judges that doing so would be commercially advantageous, without any client authority
• d.Sold to fund the firm's operations

The Securities and Futures (Client Securities) Rules require client securities to be properly safeguarded and segregated from the firm's own assets, held in a designated client account or registered appropriately, and not dealt with except with the client's authority.

To detect errors and misappropriation, a firm should regularly:

• a.Reconcile client money and client securities records against bank and custodian statements✓
• b.Rely solely on the dealer's memory
• c.Compare this year's total client balances against last year's total, and treat any difference of less than one hundred per cent as requiring no further investigation
• d.Avoid checking client balances

Regular reconciliation of internal records of client money and client securities against external bank and custodian statements is a key control for detecting errors, shortfalls or misappropriation of client assets.

A firm's controls over employee dealing typically require staff to:

• a.Route their personal trades through client accounts, mixing them with client orders so that individual staff transactions are harder for compliance to identify
• b.Never disclose their personal trades to the firm
• c.Deal through monitored accounts and, where required, obtain pre-clearance, so the firm can detect front running or insider dealing✓
• d.Trade anonymously through overseas brokers

The Internal Control Guidelines and Code of Conduct expect firms to monitor employees' personal dealing — requiring dealing through identifiable accounts and pre-clearance where appropriate — so conflicts such as front running or insider dealing can be detected.