The FCA has ramped up its crackdown on insider dealing, with a flurry of enforcement actions wrapping up in late 2025 and early 2026. Tackling financial crime remains a key priority under the FCA's five-year strategy, and recent cases involving oil rig consultants, financial advisers, seasoned traders, and investment bank employees illustrate the breadth of the regulator's enforcement reach.
Recent enforcement actions
Russel Gerrity: Oil rig consultant fined £309,843
The FCA fined Russel Gerrity £309,843 after he profited £128,765 from trading on inside information obtained through his work as an oil and gas consultant. Between October 2018 and January 2022, Mr Gerrity had early access to information about drilling results and exploited this position by purchasing shares in Chariot Oil & Gas Limited and Eco (Atlantic) Oil and Gas Plc ahead of positive announcements, and selling before negative news became public.
The FCA was initially alerted through suspicious transaction reports submitted by a firm, but its own surveillance systems subsequently identified further suspicious trades across multiple accounts with different brokers, including whilst Mr Gerrity was based outside the UK. Mr Gerrity settled the matter and qualified for a 30% discount; without settlement the penalty would have been £387,448.
Neil Sedgwick Dwane: Adviser banned and fined £100,281
The FCA fined Neil Sedgwick Dwane £100,281 and imposed a prohibition order preventing him from working in UK financial services following insider dealing in ITM Power shares. In 2022, whilst working as an adviser to ITM Power Plc, Mr Dwane had advance knowledge of an announcement that would cause the company's share price to fall by approximately 37%.
The day before the announcement, he sold 125,000 shares held by himself and a family member for £124,287, then repurchased 180,000 shares after the price declined, realising a gain of £26,575. As an experienced financial professional, Mr Dwane was well aware his conduct amounted to insider dealing and represented an abuse of his position of trust. He also failed to obtain ITM's required permission before dealing in its shares.
Matthew and Nikolas West: Brothers sentenced and ordered to pay £280,000
Matthew and Nikolas West were sentenced for insider dealing following an FCA prosecution. Matthew West received 15 months' imprisonment (suspended for two years) plus 200 hours of unpaid work; Nikolas West received six months' imprisonment (suspended for 12 months).
The brothers, both experienced traders with over 20 years in the industry, coordinated trades within minutes of Matthew receiving confidential information about upcoming AIM capital raisings, making a profit of £44,164. The court ordered them to pay back more than £280,000—the full value of shares traded, not merely their profit. Matthew received the inside information through legitimate broker communications subject to strict confidentiality obligations, but unlawfully disclosed it to Nikolas.
Enhanced detection capabilities
These recent enforcement actions demonstrate the increasing effectiveness of the FCA's multi-layered approach to detecting insider dealing. The regulator now benefits from two complementary surveillance mechanisms that together create a comprehensive monitoring framework.
Suspicious Transaction and Order Reports (STORs), which firms are required to submit when they identify potentially suspicious trading activity, provide valuable intelligence from market participants who are often best placed to spot unusual patterns in their clients' behaviour. The Gerrity case exemplifies this: the FCA was initially alerted through a STOR submitted by a firm that had identified concerning trading patterns.
However, the FCA is not solely reliant on industry reporting. The regulator has invested significantly in its own market surveillance technology, which continuously analyses trading data across multiple markets and accounts. The FCA's systems were able to identify additional suspicious trades by Mr Gerrity across multiple accounts with different brokers – including trades executed whilst he was based outside the UK – that had not been captured by the initial STOR.
Similarly, in the Sharipov and Avazov case, the FCA's market monitoring systems independently identified suspicious trades in 2021, demonstrating the regulator's capacity to detect potential misconduct without relying solely on industry reports.
Practical implications for market participants
For issuers and their advisers
Firms can mitigate reputational and regulatory risk by implementing robust procedures for handling inside information and fostering a culture that actively discourages unlawful disclosure. Written policies and procedures have limited effectiveness unless accompanied by cultural practices that reinforce compliance expectations.
For individuals with access to inside information
The recent cases provide several clear lessons for individuals who may have access to inside information in the course of their employment or professional activities:
- Internal controls must be respected: Mr Dwane was required to obtain ITM's permission before dealing in its shares but failed to do so. Even where trading might otherwise be lawful, failure to comply with internal clearance procedures may indicate awareness of wrongdoing and will attract regulatory scrutiny.
- Disclosure to family and friends is unlawful: The West brothers' case demonstrates that disclosure of inside information to family members or close associates – even where the discloser receives no direct financial benefit – constitutes unlawful disclosure and will be prosecuted.
- Wall-crossing obligations are strict: Matthew West received inside information through legitimate broker communications subject to strict confidentiality agreements, but unlawfully disclosed this information to his brother. Individuals who are wall-crossed must understand they are subject to non-trading and confidentiality obligations, and that breach of these obligations constitutes a criminal offence.
Conclusion
These enforcement actions suggest both that the FCA is adopting a proactive approach to market abuse, and that its monitoring systems are increasingly effective in spotting suspicious trading activities. The combination of industry STORs and the FCA's own surveillance technology creates a detection framework that is proving increasingly difficult to evade. Market participants should anticipate continued regulatory scrutiny and ensure their systems, controls, and organisational culture are adequate to prevent unlawful disclosure and insider dealing.