This is the scratching point of Investment Services Compliance Officers (RCSI) in financial institutions: the system for monitoring employee personal transactions.
Certain employees, said to be sensitive by virtue of their function, may carry out such operations but under certain conditions (for example, no return trip on a value in less than 30 days) and with an obligation to report monthly. Others, less numerous, said to be hyper-sensitive, are quite simply prohibited from doing so and can only manage their securities account with UCIs and not “live” securities, or else they must entrust their management to an agent.
The aim is to protect both the company and the employees from any suspicion of insider trading. This does not prevent the RCSI from having to systematically remind those who must and do not do so. When they are not being outright swindled by an administrator, who does not understand in the name of what he should stop managing his personal portfolio.
The itching hair of any RCSI. Except one: that of Bafin!
The Frankfurter Allgemeine Zeitung informs us that the ongoing investigation following the fall of Wirecard shows that BaFin officials made Wirecard the number one value in their personal transactions, even as their boss publicly called short sellers 'Agents of destabilization'. Better still: it is within the department for monitoring market abuse that we have speculated the most ardently on Wirecard!
It is beyond comprehension that no device for monitoring personal transactions is implemented by Bafin. Decidedly, German rigor is not what it used to be 😉