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.
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.