Kelvin Dickenson is Chief Product Officer at StarCompliance, with the mission to be the top global partner for employee & firm compliance.gettyA growing share of financial activity is moving beyond traditional exchanges and brokerage accounts, becoming invisible to existing compliance frameworks and controls. What was once a clearly defined environment, where trading flowed through monitored accounts and regulated venues, is now fragmenting across new market structures, extending beyond traditional exchanges. Activity is increasingly moving to crypto/digital exchanges and platforms where real-world assets such as Treasurys, equities, exchange-traded funds and commodities can be traded as tokens and exist only in a wallet. Increasingly, both off-chain and on-chain prediction markets allow individuals to profit from material nonpublic information by speculating on corporate or other economic events. Together, these represent a rapidly expanding, complex and opaque world of financial activity that sits outside many of the surveillance systems firms rely on today. The new blind spots create a space where employees can manipulate markets and trade on material nonpublic information (MNPI) without being easily detected.Momentum Is Building This shift is not speculative. It is already underway and accelerating. Based on recent data, the tokenized real-world asset market has grown significantly in both size and activity:• Just since 2025, tokenized assets have grown to a market cap exceeding $19 billion, while crypto commodities have surged to $5.5 billion.• Tokenized gold generated $90.7 billion in trading volume in Q1 2026 alone, surpassing total activity from the previous year.• Tokenized equities, while smaller at roughly $0.5 billion in market cap, produced $15.1 billion in trading volume in the same period.• Tokenized ETFs are approaching $0.3 billion in market size. Prediction markets are following a similar trajectory, with increased participation across political events, economic indicators and corporate outcomes. These markets allow participants to take positions speculating on future events in ways that can resemble trading on privileged information rather than public analysis. That dynamic is already drawing scrutiny. Platforms such as Kalshi and Polymarket have updated their rules to prohibit trading based on stolen confidential information or illegal tips and to restrict participation by individuals who may influence outcomes. The result is a market environment where information advantages can be acted on in real time, often without the surveillance and controls that exist in traditional systems. A New Channel For Insider Risk The concern is not simply that these markets are growing but how they function. Prediction markets, whether off-chain or on-chain, introduce a direct mechanism for acting on MNPI, allowing participants with early or privileged insight to take positions before information becomes widely available. Unlike traditional securities markets, where insider trading frameworks are well established, these environments operate with less clarity and fewer controls, creating uncertainty around how risk should be defined and monitored. Tokenized assets introduce a related challenge. By creating blockchain-based representations of traditional instruments, they allow economic exposure to shift into environments that may not be captured by existing compliance controls. In both cases, the signal of insider activity is becoming less about who someone is and more about how and when they act across fragmented markets. Why Traditional Controls Are Falling Short Most compliance programs were designed around a set of assumptions that no longer fully apply: • Trading occurs through identifiable brokerage accounts.• Assets classes clearly categorized within established regulatory frameworks.• Access to MNPI is tied to defined roles and relationships. These assumptions break down in newer markets:• Digital wallets replace traditional accounts, may be pseudonymous and are invisible to traditional monitoring methods.• Markets can form without centralized intermediaries. Information advantages can exist outside formal organizational structures. As a result, firms are often monitoring where trading used to happen, not where it is increasingly occurring. This creates a structural blind spot. Most employee compliance programs do not monitor blockchain wallets, digital platforms, exchanges or prediction markets. Policies often fail to address tokenized assets and nontraditional trading activity, while surveillance systems still rely primarily on traditional broker and exchange data, leaving much of the decentralized and on-chain environment unmonitored. In short, employees can now execute transactions in the new infrastructure that would be prevented in the traditional world. There exists an open invitation to circumvent the controls designed to prevent insider trading.Closing The Gap Addressing this shift requires more than incremental updates to existing policies. It requires a broader view of market activity and a different approach to surveillance. Firms need to extend visibility beyond traditional accounts, incorporate blockchain data into monitoring workflows and evaluate risk based on a wider range of asset classifications. Equally important, they need the infrastructure to interpret this data in a meaningful way. For many organizations, this is where partnering with a regulatory technology provider becomes critical. Firms such as ours are working to bridge the gap by delivering integrated surveillance, data aggregation and policy enforcement across both traditional and on-chain environments. This allows compliance teams to move from fragmented visibility to a more unified understanding of employee behavior and market exposure. The Risk Is Already Here Regulatory frameworks will continue to evolve, but enforcement does not wait for perfect clarity. As activity in these markets grows, expectations will rise alongside it. Firms that recognize this shift early and invest in the right infrastructure will be better positioned to manage emerging risks. Those that rely solely on legacy models may find themselves reacting after the fact. Because the next insider trading case is unlikely to originate from a traditional brokerage account, and by the time it does, it will reflect a market structure many firms have yet to fully address. Closing that gap will increasingly depend on regulatory technology partners to deliver the innovation, visibility and integration needed to keep pace with the evolving market.
Insider Trading Risk In The Shadows: New Markets Creating The Next Compliance Blind Spot
Regulatory frameworks will continue to evolve, but enforcement does not wait for perfect clarity.







