Expert network compliance that reads every call, joins the words to the trades and leaves the decision to the CCO
Every expert-call transcript reviewed, each MNPI flag on the CCO's desk with its proof.
See one case, screen by screen ↓Expert Network Compliance is insider trading compliance software built for expert calls at asset managers and hedge funds: it pre-clears expert calls and flags possible MNPI in transcripts for compliance review. Six agents test each expert's five years of employers against the restricted and watch lists, read every transcript in full, test each flag against the public record and check the trades after the call. A compliance analyst prepares, the Chief Compliance Officer decides, and every step is on the audit trail.
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Expert network compliance is the program that lets analysts speak with former executives, suppliers and customers without letting material nonpublic information (MNPI) into a portfolio. Section 204A of the Advisers Act requires policies reasonably designed to prevent its misuse. Today the pre-clearance is a form that trusts the network's profile, a compliance analyst chaperones a fraction of the calls, a few English transcripts are sampled by hand, and the trades after the call sit in a different system.
The SEC's April 26, 2022 risk alert named the gaps: calls not tracked and logged, notes from the calls not reviewed, and trading in the companies and industries discussed not reviewed. The SEC can bring an action for a policy failure without alleging any insider trading. So an expert with an undisclosed current contract, a passage on last week's orders and a sell order staged twenty minutes after the call can all pass unseen — and an exam request becomes weeks of assembling email, shared drives and spreadsheets.
Estimated split for one compliance analyst at the demo firm, with about 2,000 expert calls a year, by hand and with the solution.
Six agents pre-clear each expert, read every transcript, test flags against the public record and check the trades; the CCO decides.
This is expert network compliance on one call. Quillfield Capital's semiconductor analyst Owen Hartley books an hour with Graham Thorne, a former Director of Procurement at Arvelle Semiconductors, through Kestrelpoint Experts. Quillfield's funds hold 2,140,000 Arvelle shares, worth $151.2M. Here is what happens next, screen by screen, in the working solution.
Priya's Today screen shows 9 requests to pre-clear, 7 of 7 transcripts reviewed, 1 red flag for a decision and 38 trades checked after today's calls. Beside it, the agents report in their own words: nine requests came in from five network portals with every attestation signed, six pass all five gates, two need a person and one expert is a current Torvane employee.
Pre-clear agent: “One is a current Torvane employee: I recommend declining.”
Each expert call request shows the analyst, the expert's last relevant employer, the network and topic, the five gates and what the agent recommends, with the SLA of one business day. Priya selects the six recommended clear in one action. The holds — a cooling-off period that ends Dec 12, and a topic naming Brennick Therapeutics, a restricted-list name — stay with her.
“Holds and declines are decided one by one, with a reason.”
Graham Thorne's history is tested employer by employer: Arvelle Semiconductors, Director of Procurement from Apr 2019 to Feb 2026, not restricted, not on the watch list, held at $151.2M and in Owen's coverage. He left 7.6 months ago against a 6-month cooling-off. Because Arvelle is held over $50M, a chaperone is booked. Priya clears the call.
Chaperone booked: Priya Raman · call recorded.
The call runs from 14:00 to 14:52 with Priya on the line. The transcript arrives at 15:31 and the Transcript agent reads all 52 minutes and 6,840 words. The call record puts the five pre-clearance gates over the transcript, possible MNPI marked in the margin, and the agents' findings beside it: one red passage and three amber.
“I read the whole call: 52 minutes, 6,840 words. One passage is red.”
“Honestly, our Q3 wafer orders were cut 30% last week.” The Transcript agent says why: specific, recent, a company source speaking as an insider, not public, and material. The Disclosure agent searched 14 public sources up to 15:33 and found nothing — Arvelle's last statement reaffirmed guidance on Aug 27. Two amber passages are shown public with a dated source: the wafer lead times in trade press and the Taichung line in Arvelle's 10-Q.
“Agents never close a red flag. A compliance analyst decides; the CCO sees every red flag within one hour.”
The passage contradicts the expert's signed attestation of no current relationship with Arvelle. The Pre-clear agent sets the current-employee gate to Hold and asks Kestrelpoint to confirm. At 15:52 the network replies: Graham Thorne has had a part-time advisory contract with Arvelle since May 2026, never disclosed. The agent recommends blocking him on every network.
Owen has no Arvelle holdings or trades in his two personal accounts. But Samir Desai, a portfolio manager on the same team, staged a sell of 120,000 AVSC in the Global Technology Equity Fund at 15:12 — $8.5M, not yet routed. Two peer trades in Torvane Microdevices and Halsey Silicon come from an ETF index rebalance and are recommended clear. The agent asks compliance to hold the staged order, and Priya holds it.
“The Trading agent reads the order management system and the personal-trading system; it never holds or releases an order itself.”
The agents draft the restriction from the evidence: add Arvelle to the watch list with the Global Technology team blocked, freeze Owen's notes on the call, keep the order held, put an information barrier around Owen and Samir, and block the expert on all five networks. Priya prepares it at 16:02. Marcus Feld, the Chief Compliance Officer, approves at 16:20 with the reason “Possible MNPI: specific, recent, non-public”.
“Approved by Marcus Feld · 16:20 · watch list 63 → 64.”
Owen opens his call and sees only that it is under compliance review, that his notes are frozen and that he should not discuss Arvelle with the portfolio team. Flagged passages, the transcript and the agents' reasoning are visible to compliance and internal audit only.
“Your call with Graham Thorne is under compliance review.”
The Evidence agent reconciles the network portals, calendars and research notes: 23 calls by seven analysts this week. It shows Ben Achterberg's missing note on a call held Oct 14, and Owen's call waiting for the CCO decision. Once Marcus decides, Leah confirms Owen's call log at 16:41.
“Confirming attests that each analyst's calls all went through pre-clearance and that notes are filed.”
The same Arvelle call, seen by the four people who carry it — what their week looked like, and what it looks like now.
Six agents pre-clear each expert, read every transcript, test flags against the public record and check the trades; the CCO decides.
Takes expert call requests from the five network portals and email, links each to the analyst, the analyst's coverage and the firm's holdings, and checks the expert's attestation is signed.
Tests five years of the expert's employers against the restricted list and watch list, the firm's holdings and the analyst's coverage; applies the current-employee, cooling-off and government-official tests; books the chaperone the policy asks for; and re-opens a clearance when new evidence arrives.
Reads every transcript in its original language with the English beside it, and marks possible MNPI in the margin with the reasons — specific, recent, company source, non-public, material — and a confidence.
Tests each flagged passage against the public record — filings, press releases, earnings-call transcripts, news and trade press, in any language — and downgrades what is already public, with the citation.
Checks personal trades and fund orders in the issuer and its industry peers for 30 days after each call, and asks compliance to hold a staged order linked to a flagged call.
Keeps the hash-chained audit trail, reconciles the weekly call logs for the Director of Research, drafts the CCO's monthly report and builds the exam pack on request.
Prepare, approve, confirm. The agents propose; a named person decides.
Ask about any call, expert, issuer or trade — or tell the agents what to do. Every answer points to its source, and any change waits for a person to approve.
Why is the Arvelle call red?
At 31:12 the expert says Arvelle's Q3 wafer orders were cut 30% last week. It is specific, recent and from a company source; 14 public sources have nothing on it, and he has an undisclosed Arvelle contract.
Who traded Arvelle after the call?
One order: Samir Desai staged a sell of 120,000 AVSC in Global Technology Equity at 15:12, twenty minutes after the call. Owen Hartley made no personal trades.
Build the exam pack for Arvelle Semiconductors
The pack covers the policy in force, the Kestrelpoint due-diligence file, the request and five gates, the chaperone note, the transcript with flags and public-record tests, the trade checks and the restriction — 49 records with hashes. You export it.
Clear the six recommended requests
All six pass the five gates; two have chaperones booked. I have selected them in the pre-clear queue; a compliance analyst confirms with a reason.
13 screens from the working solution, on its sample data. Pick one to see it large.
The pre-clearance gates, flag thresholds and trade-check window are settings. Every change is a new policy version with a reason, live only once the CCO or Deputy CCO approves it.
| Setting | Default | Choose from |
|---|---|---|
| Employment lookback | 5 years | Changed with a reason — annual policy review, regulatory change or CCO instruction — and a second approver |
| Cooling-off after leaving an issuer | 6 months | Changed with a reason and a second approver |
| Cooling-off for government officials | 12 months | Changed with a reason and a second approver |
| Current employees of public companies | Never consulted | Fixed by policy |
| Chaperone required | Former employee within 24 months · healthcare experts · issuers held over $50M | Fixed by policy |
| Red flag at | 85% confidence or more | Changed with a reason and a second approver |
| Amber flag at | 60–84% · below that, logged, not flagged | Changed with a reason and a second approver |
| Trade-check window | 30 days · issuer and industry peers | Changed with a reason and a second approver |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published sources (SEC Division of Examinations risk alert on MNPI compliance, April 26, 2022; Advisers Act Section 204A and Rule 204A-1; Rule 204-2 on five-year retention; McDermott Will & Schulte interview on expert networks and MNPI, July 15, 2026, on chaperones as a deterrent). People, companies, funds, issuers and experts named on this page are fictional — characters and sample data in the working solution.
Expert Network Compliance is insider trading compliance software built for expert calls at asset managers and hedge funds: it pre-clears expert calls and flags possible MNPI in transcripts for compliance review. Six agents test each expert's five years of employers against the restricted and watch lists, read every transcript in full, test each flag against the public record and check the trades after the call. A compliance analyst prepares, the Chief Compliance Officer decides, and every step is on the audit trail.
The Transcript agent reads every transcript in its original language, with the English beside it, and marks passages that are specific, recent, from a company source, non-public and material — red at 85% confidence or more, amber from 60%. The Disclosure agent then searches filings, releases and news for each one and downgrades only with a dated public source. A compliance analyst decides every flag; red flags reach the CCO within one hour.
Each request from a network portal is run through five gates: five years of employment, the restricted list, the watch list, a current-employee test and a chaperone booking where the policy requires one. The Pre-clear agent recommends clear, hold or decline with its reasons; a compliance analyst decides. If the transcript later contradicts the clearance, the agent re-opens it and asks the network to confirm.
Not on its own. Practitioners describe an expert network chaperone's presence on the call as a deterrent, and one compliance analyst can attend only a fraction of calls. The solution still books chaperones where the policy asks — former employees within 24 months, healthcare experts, issuers held over $50M — and then reads every call afterwards, chaperoned or not.
The SEC Division of Examinations' risk alert of April 26, 2022 faulted advisers whose MNPI policies under Section 204A did not track and log expert network calls, did not review the notes from them, and did not review trading in the companies and industries discussed. Expert Network Compliance logs every call, reads every transcript and checks the issuer and its industry peers for 30 days after each call.
Yes. The Trading agent checks the analyst's personal trades and the funds' orders in the issuer and its industry peers for 30 days after each call. When a staged order follows a flagged call, it asks compliance to hold it; the agent never holds, cancels or releases an order itself, and the portfolio manager sees the hold but not the reason.
Yes. The agents recommend and draft; a compliance analyst clears, holds and prepares restrictions, the CCO approves with a reason code, and the Deputy CCO holds the second key on the CCO's own proposals, list removals and exceptions. No one can approve what they prepared.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your expert network policy and code of ethics, your restricted and watch lists, and a sample of past call requests and transcripts — and it goes live once every quality gate has passed. We will walk you through it on your own expert calls first.
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