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Global trade surveillance regulations: US, EU, and APAC guide

In this article, we present the key regulations across the US, EU, and APAC, the challenges of cross-border compliance, and how firms can build a unified approach that regulators trust.

Published 2025-09-09
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Global trade surveillance is no longer about meeting local rules in isolation; instead, it requires a coordinated approach across jurisdictions. In this article, we explore the key regulations across the US, EU, and APAC, the challenges of cross-border compliance, and how firms can build a unified approach that regulators trust.

Why global compliance is a 2025 survival skill

Markets no longer operate in isolation. A single transaction can fall under the watch of multiple regulators across continents. 

This means a surveillance failure in one jurisdiction can have ripple effects worldwide, both financially and reputationally.

Global enforcement actions for market abuse and surveillance failures total billions of dollars. Regulators are looking for more than just proof of monitoring; they want systems that are explainable, fast, and consistent across borders.

"When entering a new market, it’s important to understand the rules of the country; for example, if Kenya becomes an interesting market, what are the rules there? The surveillance system needs to be adapted to the country’s regulations. Thorough knowledge of local rules and regulations is essential."

- Per Friberg, Senior Financial Crime Surveillance Officer at Trapets

Regulations at a glance

In the European Union (EU):

  • Key regulations: Market Abuse Regulation (MAR), Markets in Financial Instruments Directive II (MiFID II), Markets in Financial Instruments Regulation (MiFIR)
  • Focus areas: Market manipulation, insider trading, and algorithmic trading governance
  • Notable enforcement trends: Cross-product manipulation focus, post-Brexit FCA divergence (the Financial Conduct Authority)

In the United States (US):

  • Key regulations: Dodd-Frank, the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Commodity Futures Trading Commission (CFTC).
  • Focus areas: Spoofing, layering, insider trading, and off-channel communications.
  • Notable enforcement trends: Record fines for communications violations, crypto market scrutiny

In the Asia-Pacific (APAC):

  • Key regulations: the Monetary Authority of Singapore (MAS), the Australian Securities and Investments Commission (ASIC), the Securities and Futures Commission in Hong Kong (SFC), and the Financial Services Agency in Japan (FSA)
  • Focus areas: Real-time surveillance, cross-border cooperation, and AI adoption
  • Notable enforcement trends: Social media pump-and-dump crackdowns, and decentralised finance (DeFi) oversight trials

Regional overviews

European Union

Under MAR and MiFID II, firms must monitor across asset classes and trading venues, detect insider trading, and manage algorithmic trading risks. The European Securities and Markets Authority (ESMA) promotes pan-EU standards, but national regulators interpret them differently, requiring firms to adjust thresholds and procedures locally. The UK’s FCA, post-Brexit, mirrors much of MAR but emphasises senior manager accountability.

United States

US surveillance rules demand precision and speed. Dodd-Frank emphasises derivatives oversight, while the SEC and FINRA focus on insider trading, spoofing, and off-channel communications. The CFTC actively enforces against layering and cross-product manipulation in commodities and futures. Notably, 2023 saw $1.8 billion in fines for unmonitored business communications, a sign that recordkeeping is a priority.

Asia-Pacific

APAC regulators are proactive in adopting technology. MAS in Singapore encourages AI for surveillance, provided models are validated and explainable. ASIC in Australia is known for strict post-trade enforcement, while the SFC in Hong Kong focuses on cross-border cooperation and social media-driven manipulation. Japan’s FSA prioritises coordinated monitoring across venues.

The challenge of cross-border compliance

Operating in multiple jurisdictions brings four key challenges:

  • Data fragmentation – Different formats, identifiers, and reporting requirements slow investigations.
  • Conflicting timelines – Near real-time expectations in one market versus T+1 in another.
  • Overlapping enforcement – One trade can trigger multiple regulatory responses.
  • Technology gaps – Legacy systems often can’t unify structured market data with unstructured communications.

How to build a multi-jurisdiction surveillance strategy

Building a multi-jurisdiction surveillance strategy

To stay ahead, firms should:

  1. Define a global policy framework: Set surveillance standards to the strictest applicable regulation, then adapt locally for thresholds and workflows.
  2. Centralise and normalise data: Combine feeds from all venues, asset classes, and jurisdictions into one enriched dataset.
  3. Adopt hybrid detection: Layer local compliance rules with AI/ML to catch evolving patterns.
  4. Coordinate globally, act locally: Use shared platforms with regional expertise to interpret and escalate cases.
  5. Invest in explainability: Regulators across all three regions demand clear, auditable reasoning for every alert.

Looking ahead: towards harmonisation

Bodies like the International Organisation of Securities Commissions (IOSCO) and the Financial Stability Board are pushing for greater regulatory convergence. Expect more shared investigation frameworks, common alert taxonomies, and alignment of crypto surveillance with traditional market rules. Firms that invest now in scalable, multi-jurisdictional systems will adapt fastest as standards converge.

Final word

Global trade surveillance is no longer a compliance checkbox, but a strategic necessity. By unifying data, processes, and technology across jurisdictions, firms can reduce risk, improve regulator relationships, and protect market integrity.