Internal controls for insider trading prevention must be implemented by CEOs and overseen by boards and audit committees. Chief Executive Officers, Managing Directors or analogous persons must establish adequate and effective internal controls to prevent insider trading, identify all employees with access to unpublished price sensitive information as designated person, preserve confidentiality, restrict communication and procurement, maintain recipient lists with confidentiality agreements or notices, comply with regulatory requirements, and perform periodic reviews. Boards and heads of intermediaries must ensure implementation; Audit Committees must review compliance annually. Listed companies must have board approved inquiry procedures for suspected leaks, a whistle blower policy, and require cooperation from intermediaries and fiduciaries in inquiries.