Services

Process Assessment

Many firms are uncertain what type or level of surveillance they should be implementing, or whether their existing arrangements are sufficient. GRSS provides an assessment of a firm’s surveillance risk, which includes  a comparison of 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.

Our Process Assessment service starts by gathering information from which we will gain an understanding of how and where your firm trades, what forms of communication you use and what processes and documentation you already have in place. This stage will include:

  • Reviewing existing MAR Risk Assessment and relevant policies.
  • Identifying trading systems, locations and venues.
  • Identifying communication types permissible within the firm (email, voice, video, messaging, use of personal devices).
  • Identifying investment strategy, mandates and trading patterns.
  • Identifying current surveillance monitoring procedures in place – screening criteria, alerts, escalation process, reporting and oversight

Once we have obtained an understanding of your current arrangements, we will perform a comparison against best practice for your business. This will typically include:

  • Compliance with record keeping requirements for both order and trading data and all forms of e-comms used
  • Recommend the type of surveillance algos that should be implemented based on the trading conducted by the firm
  • Recommend how e-comms surveillance should be implemented to ensure that alerts are relevant and tailored and encompass all channels
  • Advise on the integration of trading and e-comms surveillance to enable trade reconstruction and provide effective surveillance that is proportionate to your business
  • Recommend enhancements to your policies and procedures, current monitoring procedures, escalation processes, governance oversight and regulatory reporting

GRSS is independent of systems providers but has strong links with most of the main providers. We can introduce you to various vendors and help with the implementation of whichever you choose.  This allows you to get set-up and running more quickly. GRSS’s surveillance experts provide set-up advice based on their experience that will allow appropriate tailoring to meet your specific demands.

Summary:  This Process Assessment review is suitable for regulated firms which: do not have a system in place; are looking to extend surveillance arrangements (for example to capture all relevant communication channels and trading venues); or want to implement a new surveillance platform.

System Assessment

The System Assessment will gather information about your firm’s current processes and controls, then undertake a surveillance assessment. This will identify potential areas for improvement based on a comparison with best practice for a similar business. The assessment 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 exercise is designed to yield practical recommendations to improve the firm’s use of its current surveillance system. Additionally, it will include suggestions on how to  increase efficiency by reducing the incidence of false positive alerts and provide the governance team with comfort that the surveillance process is appropriate and suitable for its purpose.

In order to understand the current surveillance arrangements, our team will gather information such as; how and where the firm trades; what forms of communication are used; and what processes and documentation are already in place. This stage will include:

  • Reviewing existing MAR Risk Assessment and relevant policies.
  • Identifying trading systems, locations and venues.
  • Identifying communication types permissible within the firm (email, voice, video, messaging, use of personal devices).
  • Identifying investment strategy, mandates and trading patterns.
  • Identifying current surveillance monitoring procedures in place – screening criteria, alerts, escalation process, reporting and oversight.
  • Results of “historical events review”. This entails reviewing alerts received and respective ratios, which parameters triggered alerts.
  • Results of “challenge to the system” via passing test data. Test data is tailored depending on the strategy and based on MAR cases prosecuted by different regulators, primarily the FCA and SEC. Different systems allow differing levels of testing, since we have to insert fictitious events into the database in order to see if the current process picks them up.  The ability to insert these events will differ according  which  system you have .

Once we have obtained an understanding of your current arrangements, we will perform a gap analysis against best practice for your business. This will typically include:

  • Compliance with record keeping requirements for both order and trading data and all forms of e-comms used
  • Recommend changes to the type of surveillance algos that should be implemented based on the trading conducted by the firm
  • Recommend changes to how e-comms surveillance should be implemented to ensure that alerts are relevant and tailored and encompass all channels
  • Advise on any changes to the integration of trading and e-comms surveillance to enable trade reconstruction and provide effective surveillance that is proportionate to your business
  • Recommend enhancements to your policies and procedures, current monitoring procedures, escalation processes, governance oversight and regulatory reporting
  • Recommendations based on results of “review of historical events”. This will include suggestions to optimize algo thresholds to reduce false flags and enhance the efficiency of alert monitoring and clearance
  • Recommendations based on results of “challenge to the system”. This ensures the surveillance programme is robust enough to highlight poor behaviours identified by regulators

Summary:  GRSS can help clients ensure that they are getting the most out of their current surveillance system. GRSS’s surveillance experts can provide a systematic approach to enhancing the effectiveness of your current surveillance system and associated processes and controls.

Core Service

Through its Core Service, GRSS will assist a firm with the design, implementation, and execution of their surveillance programmes, including reviewing associated controls and processes. 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.

Many of the elements of the Process Assessment and System Assessment modules are included and implemented with results fed back to the firm. We will assist the firm to improve the effectiveness of the system already in place as well as ensuring the processes, controls, reporting and governance are in line with best practice.

There has been a proliferation of RegTech solutions specifically in the field of surveillance. The problem for regulated firms, and specifically their compliance departments, is not just which system to buy, but how to use it effectively.   

These systems will generally produce a large number of flagged actions or events based around default alert categories. GRSS will use the information gathered about a firm’s investment process to tailor alerts in order that they are relevant to mandates, trading venues, investment style etc. Managing these alerts, even once tailored to an individual firm, requires significant experience in their: interpretation; prioritisation in terms of severity; and escalation. GRSS’s surveillance experts will become a key resource to the firm’s existing compliance team by managing the bulk of the firm’s surveillance programme and assisting with the ongoing tailoring of system alerts.

GRSS will perform the ongoing daily alerts review of both trading and e-comms, escalating to the compliance officer as necessary in line with agreed criteria. We will produce regular reports identifying the results of the monitoring. Ongoing reviews of the process are undertaken by the GRSS team in consultation with the firm, ensuring any strategy drift or new communication channels are captured.

Summary:  Through its Core Service offering, GRSS can help a resource-constrained compliance department ensure its surveillance process is operating at its maximum efficiency and effectiveness.

Nic Image

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 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.

Nicole

Nicole Spiteri
Office Manager

Nicole is a skilled administrator with over ten years of experience working within Pensions, Trust, and Compliance companies, providing first-class customer services to clients, IFA’s, Intermediaries, and dealing with banks and investment companies. 

Nicole’s most recent role was that of Onboarding Analyst with ACA Mirabella. She worked closely with the Senior Compliance and GRC teams. She was responsible for undertaking due diligence checks on new clients (firms and individuals), updating existing due diligence documentation, and drafting risk assessments.

Nicole holds a Foundation Certificate in Trusts Law and Management, a Diploma in Financial Advice, and is currently working towards a Diploma in Business and Management.

Martha

Martha Cachia
Head of Administration

Martha started her career in the Financial Services Sector in 2006. She worked for well-established Financial Services Providers, in Malta. Her last role was at Mirabella which started in 2018 for two years, as an Onboarding Associate, conducting due diligence on both individuals and entities who wished to rent Mirabella’s regulatory permissions. 

Martha has a Diploma in Business Management with University of Chester administered by Global College Malta, in 2019. She has also completed the CF1 UK Financial Systems, Regulation & Ethics Certificate, in 2014.

Eliz

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.

RF

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.

TJ

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.

PS

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

George Camilleri
Head of Risk & 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

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.

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Joe Vittoria
CEO

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.