Case study
A Tier 1 Bank · Markets, FX Electronic Trading
At a glance
The engagement
A Tier 1 bank entered an enforceable undertaking with its regulator over conduct in its FX business. Capmark was engaged within the markets business to design and deliver the control uplift across the eFX algorithmic trading platform and the Barracuda order management system, working to a remediation plan reviewed by an independent expert appointed under the undertaking.
The challenge
The enforceable undertaking put the FX business under direct regulatory scrutiny with fixed remediation milestones. Pre-trade controls on the eFX algorithmic trading platform did not meet the standard the regulator expected, monitoring and surveillance of algorithmic order flow was incomplete, and order handling through the Barracuda OMS lacked the controls and audit trail to evidence fair client outcomes. Every deliverable would be reviewed by an independent expert before it counted.
Our approach
We worked desk by desk across the eFX business, designing the control framework, delivering the platform change and preparing the evidence the independent expert required.
01
Designed and uplifted pre-trade and at-trade controls across the eFX algorithmic trading platform: price tolerance checks, credit and exposure limits, throttles and kill functionality, each traced to an obligation in the undertaking.
02
Built out real-time monitoring of algorithmic behaviour and post-trade surveillance of FX order flow, with alert workflows, case management and management reporting that made anomalies visible and actionable.
03
Uplifted order handling through the Barracuda order management system: order-state controls, audit-trail completeness and exception handling, so every client order could be evidenced end to end.
04
Prepared the control documentation, testing evidence and traceability packs for the independent expert appointed under the undertaking, and remediated review findings through to closure.
05
Maintained the obligation register and provided consolidated remediation reporting to executive governance and the regulator through the life of the undertaking.
The outcome
The controls, monitoring and surveillance of the eFX algorithmic trading platform and the Barracuda OMS were uplifted to the standard the undertaking required, evidenced through independent expert review, and the obligations were closed out with the regulator.
More client results
Capital Markets · Operating Model
Global Investment Bank
Read the case study
Capital Markets · Regulatory Transformation
Leading Investment Bank
Read the case study
Get in touch
From a one-month gap analysis to a multi-year transformation programme, we engage at the stage that fits. Talk to a Partner about what good would look like.