Case study
Leading Investment Bank · Equities, Derivatives, Commodities, FX, Credit & Rates
At a glance
The engagement
We delivered a comprehensive MiFID II programme for a leading investment bank, covering RTS 6 algorithmic controls, Direct Electronic Access (DEA), market-making obligations, CCP clearing and AI-powered surveillance, enabling compliant market making and best execution across six asset classes.
The challenge
With MiFID II deadlines approaching, the bank lacked granular RTS 6 pre-trade controls and kill functionality. Market-making obligations varied by venue across asset classes, while CCP connectivity was inadequate for cleared derivatives. Buy-side clients needed real-time control over order routing and a cost-effective way to meet their MiFIR transaction-reporting obligations without building in-house infrastructure. Surveillance systems generated excessive false positives, creating regulatory risk.
Our approach
We delivered four integrated workstreams covering algorithmic controls, delegated reporting, market making and surveillance.
01
Deployed pre-trade controls (price collars, order limits, kill switches) and DEA governance. Implemented a Dynamic Algo Control Portal enabling clients to modify order routing rules, select strategies and adjust urgency in real-time across all asset classes.
02
Built delegated transaction-reporting infrastructure under MiFIR: the bank submits reports to an ARM on clients' behalf, sparing them in-house systems, with the reconciliation and controls clients need to evidence the data — responsibility for its quality stays with them. Integrated with the Dynamic Portal for a unified execution and compliance workflow.
03
Built automated quoting engines with venue-specific logic (dynamic spreads for Equities, curve-aware pricing for Rates/Credit, locational optimisation for Commodities, 24-hour FX coverage), meeting RTS 8 market-making agreements and quoting obligations. Implemented CCP clearing connectivity with give-up, allocation and automated margin and collateral workflows for cleared derivatives (IRS, CDS, Futures).
04
Deployed machine-learning surveillance models to detect manipulation (layering, spoofing, FX fix abuse) with cross-asset monitoring across all six asset classes. Implemented RTS 27/28 reporting with asset-class-specific TCA analytics.
The outcome
Full MiFID II compliance achieved across six asset classes, with the algorithmic-trading control regime under RTS 6, market-making obligations under RTS 8 and best-execution reporting under RTS 27/28 all implemented and evidenced. Market-making agreements were retained on 80+ venues. SPECS, the client-facing routing-control portal, together with the delegated reporting service, drove buy-side adoption: clients could select and control routing while avoiding the cost of their own reporting infrastructure. CCP infrastructure supported $50bn+ cleared derivatives volume, and machine-learning surveillance reduced false positives in manipulation detection. The platform secured mandates from systematic hedge funds and asset managers.
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