How Buy-Side Firms Handle Expert-Network Conflict-of-Interest Screening: 7 Structures

Conflict-of-interest screening is the compliance gate buy-side firms run before an expert is cleared to take a call, and it sits separately from MNPI review, credential vetting, and the chaperone workflow. Where MNPI screening asks whether the content of a call could contaminate the fund, COI screening asks whether the expert should be on the line at all: are they currently employed by a restricted name, sitting on a board that carries fiduciary duty, bound by an NDA the engagement would breach, or double-booked in a way that signals thesis leakage. Each of the structures below answers a different piece of that question, and most compliance teams stack several of them rather than picking one.

1. Restricted-List Cross-Check

The first gate is mechanical: before an expert profile is offered to the fund, the expert network checks the expert's current and former employers against the fund's restricted list. Because the restricted list is itself sensitive information , it reveals what the fund holds, is building, or is actively trading , the intake is usually a hashed or tokenized feed rather than a plaintext file. Both Guidepoint and GLG document restricted-list intake workflows in their published compliance materials.

The practical effect is that the expert never sees the list and the fund never sees the full expert roster. The network sits between them and returns a filtered candidate set. When this gate is skipped or run late in the workflow, the fund usually finds out only after a profile is presented, at which point the compliance officer has to decline and the moderator has to re-source. Running it first is cheaper for everyone.

2. Current-Employer Exclusion Windows

The second structure is a hard rule that no current employee of a public issuer under coverage can be engaged. It shows up most consistently at long-only mutual fund complexes, where the compliance posture is more conservative and the trading cadence is slower, but a version of it exists at nearly every fund that touches expert networks.

Enforcement runs off the employer field on the expert profile, with a cooling-off period once the expert departs. Six months is the common floor, with 12 to 24 months applied to sensitive roles or restricted names. The distinction between this and the next structure matters: current-employer exclusion is a binary gate on who the expert works for today, while cooling-off is a graduated gate on how recently they left. Funds that collapse the two into a single rule tend to over- or under-screen depending on which side of the collapse they land on.

3. Former-Employer Cooling-Off Periods

Cooling-off governs how much time must have passed since the expert last drew a paycheck from the target company. Third Bridge and AlphaSights publish standard 6-month minimums as the network-level floor, and individual funds layer their own periods on top.

The layering is where the variation lives. A generalist long-only might accept the 6-month floor for most roles. A sector-focused hedge fund often requires 12 months or more for C-suite and finance-function experts, on the reasoning that a departing CFO carries a longer-lived information advantage than a departing regional sales lead. Some funds also treat the cooling-off clock as pausing if the expert returns to the company in any capacity, including advisory work, which is why structure #6 exists.

4. Employer NDA and Garden-Leave Attestation

The fourth structure is a written attestation from the expert that the engagement does not breach any current NDA, non-compete, or garden-leave obligation. Networks including ProSapient and Dialectica surface this as a pre-call checkbox the expert must clear before the call is confirmed.

The attestation is not a substitute for the network's own diligence, but it shifts a specific legal exposure onto the expert and creates a documented record if a former employer later objects. The most common failure mode is the garden-leave case: an expert who has formally left a company but is still on payroll, still bound by exclusivity, and still carrying live information. A well-designed attestation asks about payroll status and exclusivity separately from the departure date, because the two often diverge.

5. Concurrent-Engagement Disclosure

This structure is the newest of the seven and the one where practice is still settling. The expert is asked to disclose how many calls they have taken on the same topic in the past 30, 60, or 90 days. The fund uses the disclosure to infer whether a competing book is running the same thesis, which is not itself a compliance problem but is a real information-leakage risk.

Some funds respond by requiring exclusivity windows on high-value experts, paying a premium in exchange for a period during which the expert cannot take calls on the same topic for anyone else. Others use the disclosure only as color, weighing the expert's answers with the knowledge that a similar conversation happened last week with a competitor. The trade-off is that tight exclusivity windows shrink the available expert pool, and on narrow topics the pool is already small.

6. Board and Fiduciary Role Screening

Board seats, advisory board roles, and other fiduciary positions are screened separately from employment because they carry MNPI exposure without an employment relationship. A former operator who now sits on the board of a restricted name is, for compliance purposes, closer to a current employee than to a former one , the fiduciary duty and the board-packet access are the reason.

The screening is usually done at the expert-network level, using the expert's disclosed roles plus a check against public board rosters and 8-K appointment filings. The common gap is advisory boards, which are less consistently disclosed than main-board seats and often do not appear in public filings. A robust screen asks the expert directly, cross-references the network's own records of prior calls, and flags any relationship that would need to be waived case by case.

7. Government and Regulator Affiliation Screening

The seventh structure applies to policy calls, expert-witness calls, and any engagement where the expert's value comes from a current or recent government or regulatory role. The screen looks for current government employment, active regulatory positions, and pending litigation involvement, because each of those creates its own category of information risk.

The compliance stakes here rose after 2024 SEC enforcement activity around political-intelligence expert calls, which sharpened funds' focus on whether an expert's government connections meant the call was effectively sourcing non-public policy information. The practical response has been tighter pre-call intake on government affiliations, more granular attestations covering active regulatory work, and, at some funds, an outright bar on engaging currently serving officials regardless of subject matter.

How the Seven Fit Together

No fund runs all seven as parallel independent checks. In practice, the restricted-list cross-check and current-employer exclusion run first because they are cheap and disqualifying; former-employer cooling-off and board screening run next because they need the expert's actual work history; NDA attestation and concurrent-engagement disclosure sit at the end of the intake as the expert's own certifications; and the government-affiliation screen is triggered conditionally by the topic of the call rather than run on every expert.

The useful mental model is that the seven structures answer seven different questions, and each fund weights the questions differently depending on its strategy, its trading cadence, and its regulatory footprint. A quant fund running a wide expert-call program cares most about mechanical restricted-list screening at scale. A concentrated long-short fund cares most about cooling-off and concurrent-engagement disclosure on the small number of experts closest to its theses. A macro fund running policy calls cares most about the government-affiliation screen.