Expert Network Compliance 101

Expert networks have been at the centre of several insider-trading prosecutions historically — the Galleon case in 2009 being the most famous. The industry response has been a robust, externally-audited compliance framework that's now table-stakes for any vendor selling to institutional clients. If you're a fund, you're an obvious target for regulator scrutiny on this. If you're a corporate, your IP-protection obligations apply too. Compliance isn't optional.

Material non-public information (MNPI) cannot be discussed in expert calls. The expert must attest pre-call that they hold no MNPI on the topic. The network must screen briefs against current-employee restrictions and against active inside-list periods at publicly-traded companies. Any vendor that doesn't explicitly screen for MNPI is unfit for institutional use.

A standard 6-month cooling-off period applies from departure date before a former employee of a publicly-traded company can be matched to a brief discussing that specific employer. Some networks enforce longer (12 months) for sensitive sectors. Shorter cooling-off (3 months) is common for non-public employers. The cooling-off rule is the single most-cited compliance protection in fund compliance documentation.

Experts must disclose active NDAs that restrict what they can discuss. They must not discuss content that would breach an active NDA. The per-call attestation captures this. From the buyer side: expect the expert to politely decline specific questions citing 'I'm under NDA on that' — this is normal and protects both parties.

Experts must disclose current commercial relationships with the topic company (board seats, advisory roles, current consulting engagements, equity holdings above a documented threshold). The network must surface these to the buyer pre-call. Some conflicts kill the match; others can be disclosed and the call proceeds. The right answer depends on the buyer's use case and is the buyer's decision.

Every call generates a documented attestation from the expert (covering MNPI, NDA, conflicts) and an audit-trail record retained for 7 years. The record includes the brief, expert profile, call recording (if consented), notes and post-call review. Regulators can request this and reputable vendors produce it on demand. If your vendor can't show you a sample audit-trail record before contract, walk away.

On top of the five elements above, GDPR (and equivalent in other jurisdictions) governs how the network handles expert and client personal data. Data residency in the EU should be the default for European buyers. Standard contractual clauses cover international transfers. EU-domiciled boutiques (like FieldSignal) often have a procurement-friction advantage here for European clients.

Healthcare KOL work follows ABPI (UK) / PhRMA (US) disclosure standards. Financial services follows MAR (EU) / Reg FD (US) restrictions. Defense work follows ITAR / export-control rules. The vendor should present sector-specific overlays in the per-call attestation when relevant.

Ask for: (a) a sample audit-trail record (anonymised), (b) the most recent external compliance audit report, (c) the cooling-off policy in writing, (d) the conflict-of-interest disclosure threshold in writing, (e) confirmation of data residency and standard contractual clauses for international transfers. Reputable vendors supply these in 48 hours.