Similar insider trading laws, different enforcement reality: An evaluation of Australian and Singaporean enforcement approaches

Singapore’s insider trading laws were originally adopted from Australian legislation. However, as we illustrate in this article, the enforcement of these laws has taken very different forms in recent years. Our empirical study identifies that the vast majority of insider trading sanctions imposed in Australia were criminal, while in Singapore the dominant sanctions were civil pecuniary penalties. Based on our empirical findings and interviews conducted with senior staff employed by the respective financial regulators, we outline a number of practical and policy objectives to explain their respective enforcement approaches, and discuss the implications for general deterrence.