ACA Insights from FCA 2024 STORS Report (Insider Dealing Dominates)

In March, the UK Financial Conduct Authority (FCA) published its annual breakdown of suspicious transaction and order reports (STORs) filed during 2024. The headline figure – 4,528 STORs received – reflects continued vigilance in monitoring for potential market abuse. While the volume remains largely consistent with previous years, the detailed breakdown offers valuable insights for compliance teams, particularly those in the asset management and hedge fund space.

This article examines the 2024 data in context, explores key themes emerging from recent FCA guidance, and shares perspectives from end-to-end governance, risk, and compliance provider ACA on how compliance teams can strengthen their surveillance frameworks in response.

STOR Volumes in 2024 – Stable on the Surface

The FCA defines STORs as notifications submitted by investment firms or trading venues when they suspect a transaction, or order may constitute market abuse. According to the Report, a total of 4,528 STORs were received in 2024, a slight increase from 4,375 in 2023 – roughly a 3.5% year-on-year rise.

Consistent with previous years, equity-related transactions accounted for the vast majority of filings. Of the 4,528 total STORs:

• 3,944 related to equity instruments
• 134 involved fixed income instruments
• 22 were related to commodity derivatives
• 18 involved FX instruments

The remaining STORs related to other asset classes, with relatively minor representation. Across all asset classes, the FCA reported that 3,945 of the STORs cited insider dealing, while 581 were flagged for market manipulation. Just two fell under the “other” category.

These figures reinforce long-standing surveillance patterns. The equity markets remain the most monitored environment due to their transparency, volume, and the maturity of surveillance systems available for listed instruments.

ACA notes that many firms now file STORs earlier in the investigation process due to time constraints around FCA expectations and incomplete internal data.

In contrast to U.S. Suspicious Activity Reports (SARs), where regulators often require follow-up within a specific timeframe, UK STORs function as proactive alerts – they flag concerns to the FCA even when a full internal investigation has not yet concluded.

This underscores the importance of systems and data integration across surveillance platforms to ensure timely and accurate STOR filing – particularly for buy-side firms, which often operate with lean compliance teams and limited manual resources.

A Complex Investigative Landscape

One of the most significant takeaways from the 2024 FCA data is that over 87% of all STORs filed involved suspected insider dealing. This mirrors past years and aligns with the FCA’s own public commentary in Market Watch bulletins, which continue to emphasise the regulatory focus on material non-public information (MNPI) misuse.

Detecting insider dealing is inherently complex. Unlike market manipulation, which can often be observed directly through order book activity or volume spikes, insider dealing requires firms to connect disparate data sources – from trade execution to employee dealing and external communications.

In Market Watch 79 (May 2024), the FCA pivots from counting alerts to scrutinising the plumbing of market-abuse surveillance. The bulletin – anchored by a peer review of nine investment banks – shows how missing data feeds, coding errors and untended parameter changes can silence alerts for years. The regulator therefore expects firms to implement end-to-end data-governance controls that verify every trade and order feed is captured and reconciled, adopt formal, risk-based schedules for testing model logic, code and thresholds, and run change-management processes that fix defects quickly without stalling on bureaucracy.

In short, robust market-abuse detection now depends less on clever analytics and more on disciplined data integrity and holistic model-testing governance.

Are Other Asset Classes Being Under-Surveilled?

The 2024 asset-class breakdown also prompts important questions about surveillance coverage. As in previous years, equities dominated, while fixed income, FX, and commodities collectively made up fewer than 200 filings.

The disparity raises the possibility that surveillance in less liquid or over the counter (OTC) markets is still in its infancy. Speaking with RegTech Insight, Marc Salter, Global Head of RegTech Sales at ACA notes that “Trade surveillance systems are more advanced and effective at handling equities, due to the maturity of systems and the availability of high quality, standardized data.”

However, market abuse can – and does – occur in fixed income and derivatives markets, particularly in the form of futures spoofing, cross-asset manipulation, and information leakage during bilateral negotiations. With regulatory attention expanding beyond traditional equities, compliance teams should assess whether their systems are sufficiently tuned to detect suspicious behaviour across non-equity asset classes.

“If firms wish to adopt and get the most return on their AI investments, then the underlying data cleanliness will be key, and as a bi product potentially increase the success of trade surveillance systems identifying more cases of misconduct,” says Salter.

European Trends – UK Flat, EU Rising

While the UK STOR volumes appear relatively flat, European market regulators are reporting an upward trend. According to the European Securities and Markets Authority (ESMA), suspicious transaction and order notifications (STORs) across EU jurisdictions increased by approximately 9% year-on-year in 2023 – a trend expected to continue.

This divergence may reflect the ongoing expansion of surveillance obligations under EU MAR and related supervisory efforts to encourage more rigorous detection practices across member states.

The contrast between the UK’s flatline and Europe’s growth reinforces the need for firms operating across both jurisdictions to harmonise their reporting thresholds and surveillance practices to meet varying expectations.

Buy Side Under Scrutiny

Recent regulatory developments have brought buy side firms along with advisors and wealth managers under the regulatory spotlight – particularly Financial Crime and Market Abuse surveillance obligations. ACA notes that buy-side firms could be uniquely well-positioned to evolve their surveillance programs, primarily due to three structural advantages:

• Fewer legacy systems: Unlike banks with complex technology stacks, many asset managers operate modern platforms that are easier to enhance or replace.
• Lower data fragmentation: Data environments tend to be more unified, enabling more effective cross-referencing of trading, dealing, and communications records.
• Smaller teams require smarter tooling: With fewer human reviewers, buy-side firms must lean on automated workflows, exception handling, and rule calibration to manage alert volumes efficiently.

These structural characteristics mean that surveillance enhancements – including broader asset class coverage, improved MNPI detection, and automated STOR workflows – are achievable with the right strategic investment.

Building a STOR-Ready Surveillance Framework

To stay aligned with regulatory expectations and mitigate evolving market abuse risks, firms might consider the following steps:

• Benchmark your STOR framework against FCA data and recent Market Watch insights.
• Regularly review alert calibration and exception thresholds to ensure they align with current market dynamics and risk appetite.
• Integrate personal account dealing (PAD) systems, expert network tracking, and communications monitoring to surface potential MNPI breaches.
• Expand surveillance coverage to fixed income, FX, and commodities – even where historical volumes appear low.
• Automate repetitive processes such as case triage and documentation to free compliance teams for higher-value tasks.

ACA’s ComplianceAlpha platform is designed to support these goals by providing modular automation across trade surveillance, employee trading, and e-communications oversight.

The FCA’s 2024 STOR data may suggest continuity, but that stability belies an increasingly dynamic compliance environment. The nature of surveillance is changing – moving from volume-based metrics to effectiveness, coverage, and rationale.

With over 90% of STORs relating to equities and insider dealing, and growing buy-side participation in reporting, firms must ensure that their surveillance programs are not only compliant – but comprehensive, agile, proactive, and future-ready.

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