Here are some of the "red flags" that IIROC looks at in insider trading.

"RED FLAGS"

There are "red flags" that indicate possible insider trading activity. Dealer Members should have trading surveillance which would detect this kind of activity and train their employees to watch for and report any suspicious client activity to management.

Since an order for an insider must be so indicated upon entry, a Dealer Member’s compliance department should have available a report of all insider trades. This may be obtained from an outside vendor or from the TSX. The report could provide a basis for trading reviews to identify the following:

• A change in the pattern of trading activity of an insider account from inactivity to trading, or from buying and selling to abruptly aggressively buying or selling a significant position in the security.

• Immediate buying or selling of a significant inside position by a new account.

• Orders placed by an insider outside of the recent trading range, for example, a buy order at $1.20 when the recent trading range was from $.90 to $1.00.

• An insider account making a significant profit on a quick flip in the security, or liquidating the security position and then re-establishing it at a more favorable price.

• New accounts that are not insiders that immediately take a substantial position in the security which is traded for a quick profit. The accounts may belong to a nominee or have received an insider tip.

• A pattern of consistent profitable trading by an insider or other account in the security prior to a news release.

• Trading activity by insider accounts and the accumulation of significant positions in the security by other accounts immediately prior to the security being placed on the Member’s Grey List or during the time the security is on the Member’s Grey List.

http://docs.iiroc.ca/DisplayDocument.aspx?DocumentID=0A1A294FFCA745258548A22F3DE1FB04&Language=en