Situation
Our client is a world-leading wholesale market intermediary that connects buyers and sellers in various financial, energy, and commodities markets. However, the company was facing numerous surveillance issues in both voice recording and electronic media, which exposed gaps in their operational services to the business and compliance. This put them at risk of fines from various regulators for lack of effective governance and robust controls. The COVID-19 pandemic has further worsened the problem by increasing the use of hybrid working and new platforms, such as Teams, to conduct regulated business activities, thereby increasing the risk of inadequate communication procedures. Regulators are putting pressure on the industry to implement better processes and proactive measures in communication and record keeping to avoid fines.
Approach
To address the issues in our clients communication and record keeping, a Communications Surveillance Programme’s PMO function was established. The project plan was strategically mapped out and resources were assigned to various projects and products. The company ensured that all communications used by brokers were recorded effectively by closing any gaps in the controls, such as the creation of runbooks. A migration project was also delivered to store all legacy communications in a central archiver. Additionally, a WORM (Write Once Read Many) project was organised and implemented to archive critical data in WORM format. The main activities included building out the WORM inventor and creating test plans.
Results
- Defined the vision of the programme and created a robust project plan for 2022 and 2023
- Implemented best practice governance structure and framework to the organisation of the project
- Migrated all legacy data into one central archiving system
- Reduced risk of fines. Approx. £100m and reputational damage for implementation of governance and controls
- Implemented the necessary technology requirements that were necessary to the business but also identified by the CFTC
