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[ S P O N S O R E D C O N T E N T ] A sea change in surveillance The past decade has seen a significant rise in sophistication and speed across many aspects of trading, but has also prompted a rising tide compliance regulation. P re-MiFID I, the surveillance of primary-market-only activity was simpler and manageable. Real-time monitoring platforms were necessary only at exchanges where the intent to ma- nipulate was visible on single order books. The calmer waters of lower electronic trading volumes meant manual intervention was feasible, and kill-switches were considered positively futuristic. With complexity and speed comes risk. Navigating the plethora of new venues that have emerged during the post-MiFID I era has forced participants to embrace more sophisticated access to electronic markets, with the introduction of smart routing and algorithmic execution on dark and lit liquid- ity. Within compliance, the more pro-active of market participants began to react to increasingly sophisticated strategies and related abuse by building more capable controls and detection. Inevitably, over that 10 years the regula- tion adapted too. Market Abuse Regulation (MAR) in 2016 was the watershed – the response to the realisation that detection of rogue trading needed to be as sophisticat- ed as the trading itself. 26 TheTrade Autumn 2017 Navigating the Perfect Storm For many still coping with the outturn of MAR, the approach of a deeper, more complex weath- er-front in the form of MiFID II could be the ultimate challenge. It will further test the fitness and appropriateness of market partici- pants’ systems and governance for the voyage ahead. In particular, the very stringent requirements of RTS6, applicable to anyone involved in algorithmic trading or offering direct electronic access to markets, takes order and trade surveillance to new levels. For First Line of Defence opera- tions, the visibility of real-time, cross-venue and multi-asset flows will require them to have highly scalable systems able to cope with significant fluctuations in through- put. Furthermore, the pace of market change will also necessitate the need for platform flexibility, ensuring the ability for market participants to optimise their sur- veillance scenarios on an intraday basis, in order to avoid drowning in false-positive indicators. Many trading firms are starting to recognise that navigating these far choppier waters with legacy technology is no longer appropriate. To those newly impacted, the sea change in requirements might seem overwhelming but in fact the oppor- tunity for green field implementa- tion at such a turning point in terms of available solutions is indeed very beneficial. Next generation surveillance The emergence of powerful real-time trade analytics platforms, combined with the use of artificial intelligence and access to vast his- toric (in some instances virtualised) tick and trade data repositories has underpinned much of this change. Likewise, next generation surveil- lance technology has the ability to reduce risk, improve business value, and with greater opera- tional efficiency. All of which has been achieved against a backdrop of fast moving and significantly more onerous requirements. The result – comprehensive, performant and intelligent monitoring is now more easily achievable, from a few important perspectives: