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Market abuse surveillance that stands up to scrutiny

Market abuse surveillance that stands up to scrutiny

Surveillance programmes are judged on operating-model strength, not tool selection: the data captured, the scenarios calibrated, the workflow that resolves alerts, the governance around them and the evidence that stands behind every decision.

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Market Conduct · Surveillance · Controls

SurveillanceMarket conductRisk & compliance

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Summary

Surveillance programmes are under pressure because regulators increasingly expect firms to demonstrate that surveillance arrangements are effective, risk-based, calibrated and governed.

A live platform is not enough. A vendor scenario list is not enough. High alert volumes are not proof of strong control.

Effective surveillance depends on the full operating model: market abuse risk assessment, data capture, scenario design, model testing, alert triage, investigation workflow, case evidence, STOR decisioning, MI, assurance and continuous improvement.

Firms need to know what risks they face, which products and channels are covered, what data feeds each scenario, how alerts are calibrated, how reviews are evidenced, when matters are escalated and how surveillance effectiveness is challenged.

This paper sets out how banks, brokers, asset managers, wealth firms, trading venues, market intermediaries and energy trading businesses can strengthen surveillance across trade, communications and cross-product monitoring.

What this paper covers

  • How the surveillance operating model works from risk assessment through investigation and assurance.
  • The difference between trade surveillance, communications surveillance and cross-product surveillance.
  • Key market abuse risks and behaviours.
  • Current regulatory expectations and enforcement themes.
  • Why owning a surveillance tool is not enough.
  • Data, platform and workflow requirements.
  • Alert triage, case management and STOR decisioning.
  • Common weaknesses and failure points.
  • Where AI and analytics can help, and where caution is required.
  • Governance, evidence and assurance requirements.
  • How Capmark helps firms assess, remediate, redesign and deliver stronger surveillance capability.

Who should read this

This paper is written for COOs, CROs, Heads of Compliance, Heads of Surveillance, Trading COOs, Heads of Markets, Legal leaders, Risk leaders, Technology leaders, Operations leaders and Transformation executives. It is relevant for banks, brokers, asset managers, wealth firms, market intermediaries, exchanges, trading venues and energy trading businesses.

Capmark perspective

Surveillance should be designed from the risk backwards.

Start with the behaviours the firm needs to detect. Map those behaviours to products, venues, desks, clients, traders, channels, data and scenarios. Then design the workflow, evidence model, governance and technology required to make the control work in daily operation.

Capmark helps firms move from fragmented tools, feeds and manual reviews to a governed surveillance control framework with clear ownership, usable data, calibrated scenarios, defensible alert decisions and continuous improvement.