No, GRSS provides regulated firms with experienced outsourced compliance and risk monitoring specialists to assess and review their surveillance protocols, and to help process the output from their trade and communications surveillance systems.

No, we are systems agnostic, and we have started partnering with a number of the market leading software providers, including: SteelEye, Fingerprint, ISS LiquidMetrix, eflow and MCO

Surveillance is an active process whereby a firm monitors its electronic communications and trading records to obtain assurance that it is complying with its regulatory obligations, including those in relation to market abuse and other financial crime. Archiving is a passive process whereby a firm ensures that its electronic records are maintained and are retrievable in accordance with record keeping requirements established by regulators.

We specialise in assisting firms to meet their regulatory obligations in relation to surveillance, rather than the provision of general compliance consulting. We can only provide the following:  

A Surveillance Process Assessment 

This is an assessment of a firm’s surveillance risk, comparing its current arrangements against best practice. For firms implementing surveillance systems for the first time, we can advise on the various system and control issues that need to be implemented, which will help to ensure that the new surveillance process is both proportionate and effective. 

A Surveillance System Assessment  

This is an assessment which will identify potential areas for improvement. This will include a review of historical and real-time data from the current system and a challenge on the effectiveness of alerts in the current setup using test data. This is designed to yield practical recommendations to improve the firm’s use of its current surveillance system.  

A Surveillance Operational Service   

We assist a firm with the design, implementation, and execution of their surveillance programmes. This managed service adds considerable value to the firm’s compliance officer by freeing up time and resources, enabling greater focus on other priorities as well as enhancing the overall effectiveness of the surveillance system.

All our services are priced using pre-agreed fixed fees so that clients know exactly what they will be paying each month.  The actual fees set will depend on the complexity of the project and essentially our estimate of the time taken to complete it effectively.  The factors that determine complexity include: the number of people in the firm; number of funds and what strategies they use; is it for eComms or Trade surveillance, or both; and the surveillance system chosen by the firm.  

The assessment services cost around £4-6,000 and the monthly core service starts at around £3,000 for simple firms, but increases in  larger firms with lots of people and funds.  We believe our price will always be attractive against the alternative which is to hire additional in-house staff.  

Whatever your size the FCA will want to see evidence of an effective surveillance system that is considered appropriate and proportionate to your business.  If you are unsure whether your current arrangements are sufficient, we can undertake an assessment based around best practice for the type of activities that you undertake. 

No, we are there to support you so that you can free up your valuable time to focus on other compliance priorities.  GRSS will never assume the responsibility of the Compliance Officer, which must be held in-house. 

We aim to provide you with a level of compliance and risk monitoring expertise that will be considered good value compared to the option of hiring such skilled individuals, with all of the associated cost and headcount impacts that would bring. 

Subject to the surveillance system that you employ, these will either be escalated directly to you through our flagging within the system, or if appropriate we will email or call you to ensure that any cases requiring your attention are brought to your attention as a matter of priority.  

No, we can help you implement a new system, and provide practical feedback in relation to polices, controls, reporting and oversight.    

GRSS can review your firm’s current surveillance system and protocols to provide you with practical feedback on its effectiveness. 

This is where GRSS can really help, through the provision of our core monitoring service. We would review the system to ensure the parameters in place are reducing the level of false positives to a minimum.  We then review the alerts from your system on a daily basis, clearing any remaining false positives and only escalating cases requiring your attention directly to you.   

We currently focus only on FCA regulated firms. 

There are various elements that make up an effective trade surveillance system, it should capture all trading venues, include orders placed as well as executed and have tailored alerts relevant to the firm’s business. It’s output should be reviewed frequently, if not daily then at least weekly.  The alert parameters should be reviewed at least quarterly.  

There are various elements that make up an effective eComms surveillance system, it should capture all channels used including messaging and video applications. It’s output should be reviewed frequently, if not daily then at least weekly.   Any channels you are not able to capture should be clearly prohibited for use by employees. Alerts should be derived from a tailored lexicon to ensure that false positives are reduced. Other elements of effective surveillance will include management reporting, governance oversight, clear policies, and staff training. 

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Nicholai Cumbo
Surveillance Analyst

Nicholai previously held the position of Senior Risk Officer at ACA Mirabella, where he was responsible for on-boarding clients, managing relationships and reviewing clients’ investment processes, risk management processes, strategy complexity, and operational arrangements. He was also responsible for compiling and submitting data for Regulatory Reporting. 

After graduating with a B.Sc. in Mathematics and Physics, he transitioned to finance, by completing a post graduate certificate in the Mechanics of Risk Management. He followed this up by sitting for the FRM and became a Certified Financial Risk Manager.


Elizabeth Mallia
Surveillance Analyst

An awardee of the Marie Curie Actions scholarship, Elizabeth built up her data crunching and analytical skills in theoretical motor neuroscience where she investigated brain mechanisms in action initiation at the Institute of Neurology, University College London.

She transferred her skillset to financial services in 2017, where she formed part of a formidable risk team at the regulatory hosting platform, ACA Mirabella. There she held the position of Senior Risk Associate, where she concentrated on risk management for funds with model-based strategies, focusing primarily on insurance-linked security investments. As part of the same role, Elizabeth worked with a subsection of the team on consolidating and improving the surveillance framework for potential market abuse of the platform’s diverse clientele, promoting an evidence-based approach in the set-up of the framework. 

Having also previously had the opportunity to study and work at various neuro-research institutions, including Karolinska Institutet, Stockholm and Radboud UMC, Nijmegen, Elizabeth brings multi-faceted experience in breaking down complex problems to facilitate custom solutions.


Ryan Farrugia
Surveillance Analyst

Ryan most recently held the position of Senior Risk Associate at ACA Mirabella, where he was responsible for reviewing clients’ investment processes, risk management processes, strategy complexity, and operational arrangements. He was responsible for monitoring clients’ trading activities daily, including risk/trading limits. Ryan was also involved with the creation of the Governance Risk Compliance Operations Unit within the company. 

After graduating with a Bachelors’ Degree in Commerce, a Post Graduate Certificate in Finance, and a Master’s Degree in Investment and Finance, Ryan spent over two years at APS Bank in Risk Management and Finance.


Tim Jukes
Senior Surveillance Analyst

For the last five years, Tim held the position of Senior Compliance Consultant at ACA Mirabella overseeing a wide range of complex and large firms on the hosted platform. 

Tim began his career at Price Waterhouse in 1986, where he qualified as a Chartered Accountant. Following qualification, Tim transferred to Hong Kong, where he spent 5 years specialising in the audit of multinational trading and finance entities. Tim spent 18 months on secondment at the Hong Kong Securities and Futures Commission developing an inspection regime for asset managers and advisers. 

On returning to the UK, Tim spent 3 years at IMRO, a predecessor to the FCA, specialising in asset management supervision. Tim subsequently undertook several senior in-house compliance and finance roles across a range of start-up and large asset managers specialising in open-ended funds and, subsequently, private equity. Tim then moved into compliance consulting with Cordium and more recently spent 5 years working at ACA Mirabella overseeing a wide range of hosted clients.


Paul Springer
Senior Surveillance Analyst

Paul held the position of Senior Compliance Consultant at ACA Mirabella, where he was responsible for monitoring some of the largest clients and most complex served by Mirabella. He is a compliance professional with 25+ years of regulatory experience. 

At ACA Mirabella, as well as implementing a compliance infrastructure at each client and conducting ongoing compliance reviews, Paul’s role encompassed oversight and review of clients’ electronic communications (employing Fingerprint) and their staff members’ personal compliance interactions (utilising Compliance ELF). 

Paul spent 5 years at the FCA (then the FSA) as the Manager of a Corporate Authorisation team, followed by approximately 20 years of compliance experience in the financial services industry. He has worked in-house and held the Compliance Officer and Money Laundering Reporting Officer roles for approximately 12 years, firstly at a broking firm which he joined at start-up, and then a hedge fund manager. Paul also spent over 3 years working at a leading compliance consultancy, providing compliance support to clients (including full-scope and sub-threshold AIFMs, investment managers and advisers).  He is a qualified Chartered Accountant.


George Camilleri
Head of Operations

George worked at ACA Mirabella for the past six years as Head of Risk Operations and managed the Malta-based Risk Team responsible for all the Firm’s risk monitoring and regulatory reporting. 

He holds an MSc in Financial Mathematics from the University of Leeds, focusing on quantitative risk management, and a BSc in Mathematics and Physics from the University of Malta. He has also taken several short courses, including the Oxford Private Markets Certificate at the Saїd Business School.

In his free time, George volunteers for non-governmental organisations within the cultural sector in Malta, having an interest in the arts, classical music, and opera.


Sarah Donnelly
Head of Sales

Sarah recently left ACA Mirabella, where she held the role of Head of Sales. In this role, she was focused on the company’s growth, from targeting new business opportunities to nurturing existing client relationships.

Sarah is working towards the CIPD Foundation Certificate in People Practice.


Joe Vittoria

Joe was most recently the CEO and Founder of the Mirabella Group. During the eight years that Joe grew the Mirabella business, it became the recognised leader in regulatory hosting in the UK. As its CEO and an experienced Compliance Officer, he was responsible for ensuring regulatory compliance of Mirabella and its appointed representative clients. During his tenure at Mirabella, the firm fully and successfully complied with its regulatory obligations, which included the FCA (UK), MFSA (Malta), and the NFA/ CFTC (USA).

Mirabella conducted a thorough surveillance process across all its clients’ activities, which included over $19bn in assets under management, across over 50 investment mandates, managed by over 200 portfolio managers and traders. The investment strategies it hosted ranged from Private Equity and Real Estate to complex credit and derivative processes, with the majority in long/short equity.

Apart from his experience at Mirabella, Joe has acted as COO to other investment management firms, which included quant, debt and credit strategies. Before starting in the alternative investment management industry in 1998, Joe worked at Salomon Brothers which he joined in 1985, after graduating from Yale with a BA in Economics.