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13 January 2021

AFME: Governance of Market Abuse Surveillance Controls: An industry perspective


The introduction of the Market Abuse Regulation in 2016, saw financial institutions implement a series of systems and controls to mitigate the risk of insider dealing, market manipulation and unlawful disclosure of inside information.

 Since then firms have needed to continually adapt and evolve their controls in order to continue to meet regulators expectations. The impact of the Covid-19 pandemic resulted in firms having to ensure their approaches were agile and able to manage the emerging risks caused by market volatility and unprecedented numbers of colleagues working from home.

 AFME in collaboration with EY, have today published ‘Governance of Market Abuse Surveillance Controls – An industry perspective’. The report provides insight into firms current state of surveillance governance and considers what the future state could look like, whilst addressing the key questions firms are actively addressing as they develop their future strategic roadmap.

 Drawing on survey responses and deep dive interviews with AFME Members and European regulators. We hope that the insights in this paper will help to frame the key aspects of this debate and provide firms with industry insight to advance the effectiveness of their surveillance governance

 The report considers five key themes:

  1. Restructuring the operation model
  2. Navigating risks through the STOR process
  3. Establishing a well governed framework
  4. Chasing completeness and
  5. A change in approach: focusing on risk driven methodologies

 This report sits alongside a series of compliance papers we have produced in partnership with EY, including the The Future of the Compliance Control Environment and the Scope and Evolution of the Compliance Function


Full report



© AFME


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