Strengthening Market Abuse and Trade Surveillance Controls to adhere with MAR

Client: Global Financial Service Organization

 

Objective

 

Assist the client in strengthening its Market Abuse and Trade Surveillance control environment by integrating New Market Abuse Regulations (MAR) and Conduct Risk Management Framework.

 

CRISIL’s Solution

 

  • The CRISIL team kicked off the engagement with a current-state assessment of the trade surveillance model, policies and procedures, including benchmarking and gap analysis (on regulatory changes).
  • Working from the results of that assessment, we designed and implemented a future state conduct risk management framework for market abuse, including new markets technology, behaviors and controls.
  • Analysed the parameters in current scenarios and further refined to reduce false positives for the markets and trade risk activities.
  • Designed and developed new policies and procedures, including controls for managing:
    • Market manipulation Risk: Algo Trading, Wash Trades
    • Trade Data Risk: Stop-Loss Triggers, Fix Manipulation
    • Suspicious Transactions: Insider Dealing, Partial Fills, Front Running, Best Execution
  • Designed, developed and implemented risk-based automated system in which alert reports can be directly loaded into integrated dashboard to easily monitor and investigate the trade alerts.

Client Impact

 

  • The client met all market abuse guidelines defined by FCA and improved its governance framework around trade surveillance in a short span of time;
  • Integrated Dashboard for alerts reports helped drive review efficiency and facilitate micro-analyses on trade risk alerts.

Key Benefits

 

  • Adherence to MAR /MAD regulations;
  • Profiling of customers to categorise associated risk;
  • Visual evaluation of results;
  • Elimination of significant manual monitoring and human errors;
  • Maximum coverage scenarios integrated for Market Abuse.

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