How Holding Companies Manage Insider Trading Policies Across Subsidiaries

Episode 48 of The Holding Company with Fexingo. Lucas and Luna explore how multi-business holding companies design and enforce insider trading policies across diverse subsidiaries—a complex challenge when material non-public information flows between unrelated business units. They examine the 2024 SEC settlement with a major holding company over inadequate information barriers, the practical mechanics of restricted lists and trading windows, and why the 'need-to-know' principle is harder to maintain when you own fifteen businesses. Lucas breaks down how one holding company centralized compliance while preserving subsidiary autonomy. The conversation covers the role of a central compliance officer, the tension between information sharing and legal risk, and the crucial difference between policies that look good on paper and those that work in practice. A focused look at a governance dimension that rarely gets attention but can cost executives their careers. #InsiderTrading #Compliance #HoldingCompany #SubsidiaryGovernance #SEC #InformationBarriers #RestrictedList #TradingWindow #NeedToKnow #MaterialNonPublicInformation #CentralCompliance #BoardRoom #Governance #BusinessPodcast #FexingoBusiness #TheHoldingCompany #Podcast #Business Keep every episode free: buymeacoffee.com/fexingo