The Hong Kong Securities and Futures Commission (SFC) has reprimanded and fined Instinet Pacific Limited (Instinet) $8 million for failing to comply with The Stock Exchange of Hong Kong Limited (SEHK) reporting requirements for direct business transactions or cross trades. An SFC investigation found that between December 2012 and March 2018 Instinet failed to report 8,817 pairs of cross trades, involving transactions worth around $25.9 billion, between its clients and an affiliated company, breaching the Code of Conduct. The SFC also found that Instinet lacked internal policies, procedures and monitoring controls for cross-trade reporting to the SEHK and did not review its trade reporting process. In setting the sanction, the SFC considered the duration of the failures, the number and value of unreported trades, and Instinet’s steps to cease the relevant trade flows and its cooperation in addressing the SFC’s concerns.