FAI COMPLY can advise on policies and procedures for the prevention of market abuse, more specifically, regarding the appropriate arrangements, systems and procedures as well as notification templates to be used for preventing, detecting and reporting abusive practices or suspicious orders or transactions.
Companies must follow certain procedures, which are all interrelated, for the purpose of detecting and reporting suspicious transactions related to market abuse and for the purposes, if possible, of prevention of abuse. Clients’ transactions shall be monitored on an ongoing basis using, among others, the key indicators (red flags).
FAI COMPLY can advise on all aspects of market abuse as follows:
Surveillance & Notification policies and procedures: guidance as to escalation, decision-making, record keeping and actual submission of notifications.
Design and implementation of tools: Design and testing of the functionality of surveillance tools.
Alert logic: Initial alert design, construction and associated analytics, ongoing periodic and event-driven alert logic updates.
Day-to-day monitoring: Automated and manual monitoring of orders, messages and transactions across in-scope trading channels.
Investigation: Filtering, investigation and closing out of flagged suspicious activity cases.
Ongoing testing and calibration: Periodic and event-driven testing of surveillance tools, ongoing calibration of tools to optimise detection capabilities to minimise volume of false positives.
External reporting, including for the submission of STORs and/or SARs to regulatory authorities.
Maintaining the company's STORs log and records of all STORs and & ‘near misses’.
Maintaining the Company Watch List for enhanced monitoring of clients identified through routine monitoring and escalations from the departments staff that require additional review, exceptions, in-depth analysis and ongoing monitoring.
External reporting, including for the submission of STORs and/or SARs to regulatory authorities.
Training
FAI COMPLY can organise and provide effective and comprehensive training to staff involved in the monitoring, detection and identification of orders and transactions that could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, including the staff involved in the processing of orders and transactions. Training is appropriate and proportionate in relation to the scale, size and nature of the business, is performed on a regular basis and at least annually and records of all employee training is retained and is available for review. For more information about how we can assist your company with the prevention of Market Abuse, please contact us on +357 25933301 or info@fai.com.cy.
Written by Constantinos Constantinides, Director of FAI Comply