On September 9, 2020, the FIA published a helpful set of guidelines for surveillance and market abuse in the UK and Europe. We have previously highlighted guidelines 5.5, 5.19, and 5.34, which generally require market participants to consider the broadest possible definition of MAR-identified behaviors, maintain triggers to prompt a review and update of risk assessments, and generate alerts tailored to the activity of the market participant. In that newsletter, we briefly described our approach in this regard.
In this newsletter, we invite you to review the section relating to your surveillance team, guidelines 5.36 to 5.46. Specifically, guideline 5.39 states that surveillance individuals should be trained appropriately with respect to their responsibilities. Guideline 5.43 talks about appropriate written procedures that set out, without limitation, the operation of surveillance arrangements and the parameters that are in place, among other governance requirements. Lastly, guideline 5.45 highlights that a market participant should apportion the responsibilities of the surveillance team appropriately.
ViP: Eventus maintains a high-touch support model that includes dedicated client relationship managers who meet regularly (often weekly) with clients and use Slack channels for instant communication and collaboration. This relationship provides for continuous training and client support. Validus’ in-depth reporting functionality allows supervisors to automatically spot check analyst’s work, monitor for changes in parameters and audit what happens to each alert. Surveillance alerts can be assigned by many factors, including account, desk or upon escalation to the appropriate surveillance or front-office team.