The DOJ table, then and now: what 25 years of insider dealing prosecutions actually show
The FCA's own conviction data tells the same story Ian Lyall told with DOJ figures in 2010: insider dealing is a steady trickle, not a periodic scandal.
When The Street Smart Trader was published in 2010, one of its sharpest pieces of evidence was a table from the US Department of Justice showing annual insider trading prosecutions going back decades. The point was simple: this is not a scandal that erupts occasionally and then gets cleaned up. It ticks along, year after year, just below public view. That table still makes the case. But there is now a UK equivalent. Here is what the FCA’s own numbers reveal.
The Short Version
- Insider dealing in the UK has been prosecuted steadily since the Financial Services Act 1986 criminalised it, but conviction rates are low and enforcement is uneven year to year.
- The FCA (and its predecessor the FSA) secured a peak of six convictions in 2016, then recorded zero from 2018 to 2023.
- After a four-year gap, the FCA secured two convictions in 2024 and stepped up enforcement activity into 2025.
- The number of investigations opened has remained consistently above zero every year, running at 14 to 26 new cases annually since 2018.
- The gap between investigations opened and convictions secured tells you most of what you need to know.
Why the book used DOJ data
Ian Lyall turned to US Department of Justice prosecution figures in The Street Smart Trader because the equivalent UK data was harder to find. The FSA, as the Financial Services Authority was then known, did not publish year-by-year conviction statistics the way the DOJ catalogued its criminal prosecutions. The US figures went back far enough to make the argument visually: dozens of cases per year, prosecution after prosecution, never quite going away.
The underlying argument applied just as well to London. The FSA had been criminalising insider dealing since the Financial Services Act 1986. Cases were moving through the courts. The City had its own version of the same steady trickle. It was just less visible.
What the FCA’s own numbers show
The FCA published insider dealing conviction data for the years 2015 to 2022 in response to a Freedom of Information request. The picture it reveals is instructive.
| Year | Convictions | Notes |
|---|---|---|
| 2015 | 2 | Including former Logica manager and former Morrisons treasurer |
| 2016 | 6 | Peak year; Schroders trader, Mark Lyttleton case, Operation Tabernula verdicts |
| 2017 | 1 | Richard Baldwin; sentenced in 2019 |
| 2018 | 0 | Six new investigations opened |
| 2019 | 2 | Walid Choucair; £3.9 million confiscation order |
| 2020 | 0 | 22 new investigations opened |
| 2021 | 0 | 14 new investigations; four prosecutions launched |
| 2022 | 0 | 22 new investigations opened |
| 2023 | 0 | |
| 2024 | 2 | First convictions since 2019; former analyst and former plastics firm manager |
| 2025 | 2+ | Korfuzi convictions (£1m scheme); Gerrity civil fine; new charges against Sharipov and Avazov |
Investigations opened in the same period ran at between 14 and 26 new cases per year since the FCA changed its recording system in 2018. Between 2015 and 2017, 118 cases were opened in total across those three years.
What the gap between investigations and convictions means
The most striking feature of the table is not the conviction numbers. It is the persistent distance between the number of cases opened and the number that reach a verdict.
Insider dealing cases are expensive to investigate, difficult to prove, and easy to defend. The FCA must establish that an individual was in possession of price-sensitive information that was not publicly available, that they knew it was inside information, and that they traded on it deliberately. Every element has to be proved to the criminal standard.
Circumstantial evidence of unusual trading activity before an announcement is common in insider dealing cases. Direct evidence of the information exchange that preceded it is rare. Conversations that happen at lunch, on personal phones, or in messages that are later deleted leave investigators with strong suspicion and weak proof.
The four-year gap in convictions from 2018 to 2023 does not mean the FCA stopped looking. It kept opening cases. The number of prosecutions launched in 2021 was the highest since 2015. The bottleneck was in court, not in investigation. Complex financial crime cases take years to reach trial, and juries need to understand what they are being asked to decide.
How MAR changed the landscape
The Market Abuse Regulation came into force in the UK in July 2016, replacing the earlier Market Abuse Directive. It widened the scope of what counts as market abuse, introduced civil penalties for insider dealing that can be imposed without a criminal prosecution, and expanded the FCA’s powers to require firms to report suspicious transaction and order activity.
The FSA was renamed the FCA in April 2013. The Market Abuse Regulation came in three years later. Between those two events, the regulatory apparatus for catching insider dealing was tightened, the reporting requirements on market participants were extended, and the civil route to enforcement became a more viable alternative to criminal prosecution.
The Gerrity insider dealing case in 2025 illustrates the civil route clearly. Russell Gerrity, a petrophysical consultant who traded on advance knowledge of oil exploration results, received a civil financial penalty of £309,843 from the FCA without going through the criminal courts. The penalty does not appear in the conviction column, but it still represents enforcement.
A Worked Example
In 2010, the year The Street Smart Trader was published, the FCA’s predecessor launched what became the largest insider dealing investigation in UK history. Operation Tabernula, running from 2010 to 2016, investigated a network of individuals passing share tips through a chain of sources inside the City.
The case involved eleven suspects, encrypted mobile phones, and millions of pounds in alleged profits. It took six years to reach trial. The eventual result was four convictions and one acquittal, with sentences of up to four and a half years in prison.
The Tabernula convictions are included in the 2016 figure in the table above. They help explain why 2016 looks like a peak year. A single large investigation, opened years earlier, producing several verdicts at once, is how City enforcement tends to work. The headline figure of six convictions was not a sign that the FCA had suddenly doubled its tempo. It was the delayed output of a case started half a decade before.
What This Means For You
The table exists for one reason: to show that insider dealing is not exceptional. It is a feature of markets, not a bug that appeared briefly and was then fixed.
Every year, new investigations open. Most close without prosecution. Some result in civil penalties rather than criminal convictions. A handful reach trial. Fewer still end in a conviction.
As a private investor, you are on the outside of this process. The trader on the other side of your transaction may or may not have access to information you do not. You have no way of knowing. What you can do is take the data seriously when you see price movements that seem disconnected from publicly available information. Unusual volume ahead of announcements, share prices that drift in one direction for days before news breaks, unexplained trading in options just before a results statement: these patterns are not always the result of manipulation, but the data shows they are rarely entirely innocent either.
In Plain English
The Street Smart Trader used US prosecution data to make a simple point: insider dealing is an ongoing feature of markets, not an occasional aberration. The FCA’s own figures for the UK tell the same story. Convictions are relatively rare. Investigations are routine. The gap between what is suspected and what is proved in court is wide.
The most honest reading of the table is this: the insider dealing cases you read about are a small fraction of what is investigated, and what is investigated is a small fraction of what takes place.
Related Reads
- Insider dealing: what it actually is, how it works, and why it still happens
- Share ramping and the bulletin board
- The City spin game
- Two questions to ask before you trade on any piece of market news
This post is adapted from The Street Smart Trader. Used with permission.
Street Smart is a series drawn from first-hand experience of the City of London, updated as each new chapter arrives.
Disclaimer: The value of investments can go down as well as up, and you may get back less than you invest. This article is for informational and educational purposes only and does not constitute financial advice. Always do your own research and consider seeking independent advice before making any investment decision.