Information Barriers Under Pressure: Can Compliance Keep Up?
Four key takeaways on strengthening MNPI governance, information barriers, and oversight in an increasingly connected world.
Financial markets are becoming more connected, and compliance teams are facing increasing pressure to manage material, nonpublic information (MNPI), maintain effective information barriers, and demonstrate that their controls are working.
In the third installment of StarCompliance’s (Star) webinar series exploring key findings and trends from its 2026 Global Compliance Benchmark Study, industry experts examined the evolving challenges of MNPI governance and what firms can do to strengthen oversight.
The webinar, Information Barriers Under Pressure: MNPI Governance in a Connected World, was hosted by Steve Brown, Head of Business Development at StarCompliance, and featured Eric Wolfman, Deputy Chief Compliance Officer and Senior Vice President at KeyBanc Capital Markets, and Andrew Kessler, Head of Control Room – Americas at SMBC Group.
Drawing on real-world compliance experience, the discussion highlighted four important considerations for firms looking to balance regulatory expectations, operational efficiency, and business needs.
1. Global Operations Require More Connected Oversight
As financial institutions expand across jurisdictions and trading increasingly extends beyond traditional market hours, managing MNPI across regions becomes more complex.
Different regulatory expectations, operating models, and regional practices can create challenges for control room teams responsible for maintaining information barriers. Ensuring that watch and restricted lists are updated promptly, particularly when transactions or trading activity occur outside normal business hours, requires effective coordination.
A global control room structure can offer advantages by providing more consistent oversight, improving information sharing, and supporting timely decisions across jurisdictions. However, the appropriate approach depends on each firm’s business model, geographic footprint, and risk exposure.
Key Takeaway:
Firms should evaluate whether their control room structure provides sufficient visibility and responsiveness across regions, particularly as global trading activity and regulatory complexity increase.
2. Connected Data Can Strengthen Surveillance
Traditional surveillance approaches often examine trading activity, employee communications, and information access separately. While these controls serve important purposes, fragmented data can make it difficult to identify connections that may signal potential misconduct.
Advances in technology are creating opportunities to bring together multiple sources of information, including electronic and voice communications, employee trading, institutional transactions, and system access records.
A more holistic view can help compliance teams better understand who had access to sensitive information, when it was accessed, and whether related communications or trading activity warrant further investigation.
However, the discussion also emphasized that technology investments must be proportionate to a firm’s risk profile. A high-volume equities business may require more sophisticated, integrated surveillance capabilities than a business with lower trading volumes.
Key Takeaway:
Connecting surveillance data can improve risk detection and investigative efficiency, but firms should prioritize technology investments based on their specific risks, trading activity, and operational needs.
3. Effective Controls Require Evidence, Not Just Policies
Having documented policies and procedures is essential, but it does not necessarily demonstrate that compliance controls are operating effectively.
Control room teams must be able to assess whether their safeguards work as intended, particularly when monitoring access to MNPI, maintaining restricted lists, and reviewing potentially suspicious trading activity.
The webinar explored the value of targeted surveillance, thematic reviews, and practical control testing. Rather than relying solely on established processes, firms should periodically examine individual controls to determine whether they are functioning as expected.
This can include reviewing employee trading against institutional activity, assessing information access, or testing whether a specific restriction was applied appropriately and on time.
These exercises can help identify gaps, improve processes, and provide evidence of program effectiveness.
Key Takeaway:
Compliance effectiveness must be demonstrated, not assumed. Regular testing, targeted reviews, and documented evidence help firms validate controls and strengthen their ability to withstand regulatory scrutiny.
4. Business Collaboration is Essential to Stronger Compliance
Effective MNPI governance depends on more than policies, technology, and surveillance. It also requires strong working relationships between compliance, legal, control room teams, and the businesses they support.
Control room professionals often work across multiple business lines, requiring a broad understanding of different products, transactions, and associated risks. Collaboration with legal and advisory colleagues can help teams navigate difficult decisions and establish consistent approaches.
Equally important is engaging business stakeholders when designing and implementing controls. Understanding how employees operate, where processes create friction, and what practical challenges they face can help compliance teams develop safeguards that are both effective and achievable.
Technology can further support this effort by simplifying compliance processes and making it easier for employees to meet their obligations.
Key Takeaway:
Compliance programs are more effective when controls are developed collaboratively, supported by business buy-in, and designed to make compliance easier without compromising oversight.
Building More Effective MNPI Governance
The discussion reinforced an important message: effective information barriers require connected oversight, risk-based surveillance, ongoing control validation, and business collaboration.
As markets evolve and information moves more rapidly across teams, systems, and jurisdictions, firms must continually assess whether their MNPI governance frameworks can keep pace.
For compliance leaders, the goal is not simply to establish more controls. It is to create a program that provides meaningful visibility, supports timely decisions, and produces evidence that those controls are working.
At StarCompliance, our Connected Compliance approach helps firms bring information, processes, and oversight together to manage MNPI, strengthen information barriers, and support more efficient, defensible compliance programs.
Watch the Full Webinar Series on Demand
Missed the conversation? Watch Information Barriers Under Pressure: MNPI Governance in a Connected World on demand to hear the full discussion and gain practical insights into strengthening information barriers, managing MNPI risk, and demonstrating compliance effectiveness.
This webinar concludes StarCompliance’s three-part series exploring key findings and trends from the 2026 Global Compliance Benchmark Study. Catch up on the first two sessions for additional insights into today’s evolving compliance challenges:
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Watch all three webinars on demand to gain expert perspectives and practical strategies for navigating emerging risks, strengthening oversight, and building more effective compliance programs. Access the series [HERE].
