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The FCA has fined two individuals for insider dealing – Mr Hirani, who was fined £56,000, and Mr Kerai, who was fined £52,731.
Article 14 of the UK Market Abuse Regulation (UK MAR) provides that a person shall not engage or attempt to engage in insider dealing – that is deal while in possession of, and using, inside information (Article 8 of UK MAR).
In December 2021, Mr Hirani was the interim Chief Financial Officer at Bidstack, an AIM-listed company that placed advertising in video games. In that role, he had access to inside information about a major upcoming deal between Bidstack and a large video game producer.
Mr Hirani passed this information to Mr Kerai before it was announced to the market. Mr Hirani then opened a trading account in Mr Kerai's name and, with his help, bought 1.3 million Bidstack shares in advance of the announcement.
When the deal was made public, Bidstack's share price rose by more than 125% and Mr Kerai made more than £9,000 in profit.
The FCA said that, while there was no direct evidence of Mr Hirani disclosing inside information to Mr Kerai, there was significant circumstantial evidence pointing to this having occurred.
The FCA says it was initially notified of the trading through Suspicious Transaction and Order Reports submitted by a firm.
Both parties received a 30% settlement discount, reducing their fines from £80,000 and £69,260 respectively.
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