Compliance teams across the globe are writing personal account dealing (PAD) policies, circulating them, and collecting signed attestations confirming staff have read and understood them.

Yet according to analysis from MCO (MyComplianceOffice), there is often a real disconnect between what a policy says and what actually happens day to day. Recent enforcement action in the United States, United Kingdom, Australia and Hong Kong illustrates a widening gap between policy on paper and risk in practice.

Kroll director Alasdair Putt, speaking on an MCO webinar, said, “detailed, rigorous, and thorough policies and procedures in place,” are not enough on their own. Putt said, “if the senior management aren’t ensuring that staff understand the compliance framework and the obligations they have as employees of the firm… then it’s easy and very likely that the breaches of the company’s compliance policies or procedures start to happen.”

The case studies MCO highlights make the point concrete. 5m in April 2024 after it failed to enforce its own code of ethics, leaving staff trading without pre-clearance. In the UK, the FCA jailed a research analyst for six years in 2025 after he routed trades worth more than £960,000 through family accounts to dodge monitoring. In Australia, ASIC jailed a corporate adviser in 2024 for trading on confidential deal information for a A$57,000 profit. In Hong Kong, the SFC fined a fund manager HK$2m and banned its former responsible officer for eight months after more than 2,500 unapproved personal trades over five years.

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