Published on: 2026-10-12
Source: Moscow Exchange –
An important disclaimer is at the bottom of this article.
Irina Grekova, Senior Managing Director for Compliance and Business Ethics at Moscow Exchange
The right question is not whether insider trading or market manipulation can be defeated, but how to make these violations inherently unprofitable. Modern regulatory policy is built precisely on this. Despite legislative differences, the trend towards increasing the efficiency of control is obvious — practice sooner or later arrives at similar solutions.
Even in countries with the strictest regulations, the fight against abuse is “supportive therapy.” The European Securities and Markets Authority (ESMA) imposed more than 970 administrative fines totaling over €100 million in 2024, mostly under the Market Abuse Regulation. The American Securities and Exchange Commission (SEC) filed 456 lawsuits in the 2025 fiscal year, recovering $17.9 billion, but simultaneously closed 1,095 investigations without charges. In both cases, the work is enormous, but violations continue — although the risks for offenders are increasing.
In Russia, the Central Bank has identified 180 cases of market manipulation and insider trading over 15 years. The expert-assessed annual damage amounts to hundreds of millions of rubles, while the proven damage for 2021–2023 is 9.4 million rubles, and the total fines are only 1.25 million rubles. The gap between profit and punishment has made the violation a rational choice. According to the Ministry of Justice, from 2021 to mid-2024, eight people were convicted for manipulation, two for insider trading, most receiving suspended sentences. A case is known of a trader from Chelyabinsk with income of 139 million rubles, who was fined 500 thousand rubles.
The case of the authors of three Telegram channels, detained in the spring of 2026, showed how difficult it is to uncover such crimes. The regulator collected evidence for almost three years: comparing publications with real trades and finding signs of manipulation. But one trader can have tens of thousands of operations — it’s a manual search for a needle in a haystack.
Signs of activity are detected quickly, but to prove them, each transaction must be examined and income calculated. As long as the cost of expertise exceeds the offender’s benefit, the coverage will remain limited even with strict sanctions. Moreover, the investigation lacks specialists in organized trading and investigative methodologies.
Global experience shows: complete victory over insider trading and manipulation is unattainable, but sustainable deterrence is achievable
The head of the Central Bank, Elvira Nabiullina, at SPIEF-2025 stated that manipulations destroy investor confidence and announced tightening measures: fines will be multiples of the illegal income. Bills have been submitted to the State Duma that could be adopted as early as this autumn.
Currently, under Article 15.30 of the Administrative Offences Code, the fine for individuals is up to 5,000 rubles, for officials up to 50,000 rubles, and for legal entities from 700,000 rubles of “excess income.” These amounts do not prevent violations. Part 1 of Article 185.3 of the Criminal Code of the Russian Federation provides for fines from 300,000 rubles to imprisonment for up to four years.
The new bills propose fines ranging from three to five times the amount of illegal income, and criminal liability applies if the damage exceeds 100 million rubles (currently 3.75 million rubles). Large-scale fraud by a group or using official position can lead to up to 12 years of imprisonment with fines up to 5 million rubles.
However, it is important not only to increase the size of fines but also to raise the threshold for administrative liability. This is needed not to make enforcement measures easier on violators but to increase the effectiveness of their implementation — administrative matters are considered, and decisions are made more promptly. This logic is confirmed by international practice: abroad, for every 1,000 administrative measures, there are fewer than 100 criminal convictions.
Global experience also provides a technological answer to the question of how to organize mass investigations of administrative cases — it is the use of AI to analyze vast amounts of trade data and identify unfair practices. This approach has already proven effective by taking on routine tasks. For example, the case of the Corfuzi brother and sister in the UK (insider trading and laundering of £1 million) was uncovered thanks to a signal from the automated monitoring system of the British regulator.
The Moscow Exchange actively uses AI tools to detect transactions with signs of manipulation and to generate materials based on inspection results. The platform began to be developed even before the introduction of legislative proposals: it became clear that the growth in operational workload requires automation for effective control.
New technologies cover the first half of the task: they make detection inexpensive and scalable, gradually displacing routine processes. The second half is addressed by potential legislative changes: speeding up the process, confiscating income instead of symbolic fines, disqualification as a measure of impact. In Russia, the Central Bank’s anonymous reporting service, launched in January 2026, has collected over 150 reports but so far without feedback.
For example, the American whistleblower program has paid out $2.2 billion to 444 whistleblowers over 15 years, 62% of whom were company insiders—something no monitoring system can replace. But this only works in conjunction with protection: the SEC filed 11 cases against companies that obstructed employees from approaching the commission, including an $18 million fine for J.P. Morgan.
Global experience shows: complete victory over insider trading and manipulation is unattainable, but sustainable deterrence is achievable. For Russia, it is critically important not just to change laws, but to build the entire chain: from rapid detection to inevitable and impactful punishment. Then manipulation and insider trading will become a game no one will want to play.
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