FCA Insider Dealing Investigation: Three Arrested as Electronic Evidence Seized

Three people have been arrested following a major investigation into suspected organised insider dealing and money laundering, with Financial Conduct Authority (FCA) investigators seizing more than 30 electronic devices during coordinated searches in London and Manchester.

The operation, announced on 13 October 2026, involved more than 100 personnel from the FCA and National Crime Agency (NCA). Investigators searched five residential properties as part of enquiries into a suspected organised criminal group.

Mobile phones, laptops and tablets were among the devices seized.

The investigation highlights the importance of financial intelligence, digital evidence and establishing connections between individuals, transactions and communications when examining suspected financial misconduct.

For businesses, legal professionals and regulated firms, the case also demonstrates how complex financial investigations may require several different forms of evidence to establish what happened.

What Has the FCA Announced?

According to the FCA, three individuals were arrested on 13 October following a joint operation with the NCA.

The regulator confirmed that searches took place at five residential premises in London and Manchester, with more than 30 electronic devices seized.

The arrests form part of an investigation into suspected organised insider dealing and money laundering.

Steve Smart, the FCA's Executive Director of Enforcement and Market Oversight, described insider dealing as a serious threat to market integrity and emphasised the regulator's determination to tackle organised financial crime.

The three individuals were being interviewed by FCA investigators at police stations in London and Manchester following their arrests.

The regulator has not publicly identified the suspects or provided detailed allegations about specific securities, transactions or financial institutions involved.

It is therefore important not to speculate about the suspected activity or the significance of particular devices.

An arrest does not establish wrongdoing, and the seizure of electronic equipment does not demonstrate that it contains evidence of a criminal offence.

Why Insider Dealing Investigations Can Be Complex

Insider dealing generally involves trading, or certain related conduct, using inside information that is not publicly available.

Such information may concern forthcoming corporate announcements, financial results, acquisitions or other developments capable of affecting the price of financial instruments.

Investigations can become particularly complicated when suspected conduct involves multiple individuals or organisations.

A relevant enquiry may need to establish when sensitive information became available, who had access to it and whether particular transactions were connected to that information.

Investigators may examine:

• The timing of trades and relevant market announcements.
• Communications between individuals.
• Corporate and professional relationships.
• Access to confidential business information.
• Financial transactions and supporting records.
• Possible connections between trading activity and the movement of funds.

A suspicious transaction does not automatically establish insider dealing.

The available evidence must be assessed within its wider context, including legitimate explanations for trading decisions and communications.

The FCA's latest operation demonstrates the scale of resources that may be required when suspected market abuse involves several individuals and potential financial relationships.

Why Electronic Evidence Matters

One of the most notable aspects of the operation was the seizure of more than 30 mobile phones, laptops and tablets.

Modern financial investigations frequently involve electronic information that may help establish the sequence of events surrounding suspected misconduct.

Relevant material can include emails, messaging records, documents, transaction information and other data stored on digital devices.

Where lawfully accessible and technically recoverable, digital evidence may assist with establishing:

• When relevant communications occurred.
• Whether documents were created, accessed or modified.
• Connections between individuals and organisations.
• The timing of activity surrounding financial transactions.
• Whether information was transferred between systems.
• Inconsistencies between accounts of events and electronic records.

However, electronic data requires careful interpretation.

The presence of a contact, message or document does not automatically demonstrate participation in wrongdoing.

Similarly, timestamps and recovered files must be assessed in context before conclusions can be drawn.

Conflict International's Digital Forensics and Investigation Services support clients requiring the preservation, acquisition and examination of electronic evidence in matters involving suspected fraud, employee misconduct and commercial disputes.

Our role is to establish what can be reliably determined from available evidence rather than assume that particular information proves misconduct.

The Importance of Preserving Digital Evidence

The way electronic information is handled can significantly affect its usefulness in subsequent investigations or legal proceedings.

Devices may contain information that changes through normal use, while messages, account records and stored files can be deleted or overwritten.

Where an organisation suspects financial misconduct, preserving relevant material should therefore be considered before unnecessary changes are made to systems or devices.

The appropriate approach depends on the circumstances, ownership of the equipment, legal authority and the nature of the suspected activity.

Specialist digital forensic processes can help maintain the integrity of relevant material and document how information was acquired and examined.

A structured process may involve identifying potentially relevant sources, determining what can lawfully be accessed and maintaining records of the examination.

Businesses should avoid conducting unnecessarily intrusive searches of employee devices or personal communications without considering legal and data protection requirements.

Where litigation or regulatory proceedings are anticipated, early coordination with legal advisers can help establish an appropriate evidence-preservation strategy.

The Relationship Between Insider Dealing and Money Laundering

The FCA has confirmed that its investigation concerns suspected money laundering as well as insider dealing.

These are distinct areas of financial crime, although they may become connected where investigators suspect that funds derived from unlawful activity have been moved, concealed or otherwise dealt with.

Financial enquiries may involve examining the source and destination of transactions, relationships between account holders and the possible involvement of corporate entities or intermediaries.

However, identifying a financial connection does not necessarily establish criminal involvement.

For example, the existence of a payment between two individuals does not prove that either participated in unlawful trading.

Investigators must distinguish verified transactions from suspected relationships and determine what additional evidence may be needed.

Conflict International's Fraud and Financial Investigation Services support businesses, law firms and private clients dealing with suspected financial misconduct, disputed transactions and complex corporate relationships.

Depending on the available information, enquiries may examine relevant payment records, company interests, associated individuals and documentary inconsistencies.

Private investigators do not have unrestricted access to confidential banking or brokerage information. Such material may require institutional cooperation, formal legal disclosure or statutory powers.

What the Investigation Means for Regulated Businesses

Although the latest operation concerns suspected criminal activity, it offers a useful reminder of the importance of maintaining effective controls around sensitive commercial and financial information.

Organisations handling confidential information may need to consider who has access to material capable of influencing market decisions.

Appropriate internal procedures can include:

• Restricting access to sensitive information according to business need.
• Maintaining relevant records of authorised access.
• Establishing policies governing personal account dealing.
• Identifying and managing potential conflicts of interest.
• Providing appropriate guidance on confidential information.
• Establishing clear procedures for escalating suspected misconduct.
• Preserving relevant information where concerns arise.

The nature of these controls will depend on the organisation, its regulatory obligations and the risks associated with its activities.

Businesses should not assume that every unusual transaction or employee relationship indicates wrongdoing.

Equally, material concerns should be assessed objectively rather than dismissed simply because the individuals involved hold trusted positions.

The FCA's latest investigation remains ongoing, and its eventual findings may provide further information about the conduct under examination.

How Independent Financial Investigations Can Support Legal Teams

Not every financial investigation involves insider dealing or the financial markets.

Commercial organisations and legal professionals may encounter similar evidential challenges in matters involving suspected fraud, misappropriation, disputed payments or allegations of employee misconduct.

A business may need to establish whether financial records correspond with contractual arrangements.

A legal team may need to examine the relationship between several companies or individuals.

An organisation investigating a suspected internal fraud may require assistance reviewing electronic communications alongside transaction records.

In each situation, the objective should be to establish the facts through reliable and proportionate enquiries.

An investigation may produce a chronology of events, identify relevant corporate relationships, highlight inconsistencies or establish which matters require further documentation.

Conflict International works with legal professionals and businesses to provide investigative support where financial, corporate and digital evidence must be examined together.

Our previous article, 238,000 Money Mule Accounts Closed: Why Following the Payment Trail Matters in Fraud Cases, explores a separate FCA development concerning suspicious accounts and the challenges of understanding financial transactions.

The latest insider dealing operation provides a different perspective, highlighting the role of communications, digital devices and potential connections between individuals in complex investigations.

How Conflict International Can Assist

Conflict International provides fraud and financial investigation, digital forensic and litigation support services to businesses, legal professionals and private clients across the UK and internationally.

Our work may involve reviewing available financial documentation, identifying relevant individuals and companies, examining electronic evidence and developing structured chronologies of suspected activity.

Where specialist digital examination is required, our forensic capabilities can support the preservation and analysis of relevant information.

The scope of an investigation is determined by the client's circumstances, the available evidence and applicable legal requirements.

We distinguish between confirmed findings, possible connections and matters that require further investigation.

Our objective is to provide reliable information that helps clients and their legal advisers assess the circumstances and make informed decisions about appropriate next steps.

Discuss a Financial or Digital Investigation

The FCA's latest operation demonstrates how suspected financial misconduct can require the examination of communications, financial activity and relationships across several individuals and locations.

For businesses dealing with suspected fraud, disputed financial transactions or potential internal misconduct, establishing the available facts is an important first step.

Conflict International can assist with proportionate financial enquiries, corporate intelligence and specialist digital forensic support.

Contact Conflict International to discuss your requirements confidentially.