失控的“编外人”——亿元罚单敲响私募内控警钟

Core Viewpoint - The recent penalty imposed by the Zhejiang Securities Regulatory Bureau highlights significant internal control blind spots within private equity firms, particularly regarding the management of IT personnel and their access to sensitive trading information [1][5][6] Group 1: Incident Overview - An IT employee from a private equity firm in Zhejiang misused his position to steal non-public trading information, resulting in profits of nearly 90 million yuan through collusive trading [1][4] - The regulatory authority confiscated the illegal gains and imposed a total fine of 177 million yuan, alongside a five-year ban from the securities market for the individual involved [4][6] Group 2: Internal Control Issues - The rapid expansion of personnel in the private equity industry has led to a need for stricter internal control systems to address compliance blind spots, particularly concerning non-registered IT staff who may access core trading strategies [2][5] - Many leading private equity firms have established affiliated technology companies to manage remote employees, but this has introduced compliance risks due to varying levels of awareness and training among IT personnel [5][6] Group 3: Recommendations for Improvement - Private equity firms should implement strict information isolation mechanisms, ensuring that IT personnel's responsibilities are limited to system development and maintenance, without access to specific trading targets or strategy logic [8] - Investment decision-related data must be encrypted and access should be restricted to essential personnel, such as fund managers, to enhance security [8] - Emphasis should be placed on training technology staff in financial risk management and compliance, incorporating mandatory risk control reviews at critical stages of code development and data usage [8][7]