Wholesale Conduct of Business

Maintaining market integrity is a central focus of regulators globally. Whilst organisations have significantly enhanced their capabilities over the last 10 years, the cross-jurisdictional nature of market activities, coupled with the scale of the impact when controls fail means that the evolution of controls to stay ahead of criminal activity is a persistent challenge. We help organisations review, enhance and implement sustainable, effective controls and risk management across their wholesale activities. We focus on key areas such as:

  • Insider dealing and market manipulation
  • Order handling arrangements
  • Trade execution
  • Trade, communication and voice surveillance
  • Customer classification
  • Conflicts of interest and control room activities
  • Personal Account Dealing
  • Benchmark activities
  • Barriers and segregation

Our team has worked on trading floors and as Heads of Compliance in wholesale banking organisations. We have deep experience of implementing surveillance technology and working with organisations to align their first line of defence supervisory controls with post trade monitoring work undertaken by compliance. Our experience means that we are able tailor solutions to meet the needs of each client, such that the business has robust, but proportionate controls in line with the commercial activities they undertake.

Retail Conduct of Business

Critical to meeting regulatory expectations is the manner in which organisations consider the fairness of the outcomes they provide for their customers. Our expertise working in and with firms across multiple jurisdictions means that we have a clear understanding of regulator expectations and how organisations must translate this into their first line of defence controls and their risk and compliance frameworks. We help our clients work across the customer lifecycle, focussing on governance, policies, procedures and controls relating to:

  • Product design and management
  • Product marketing
  • Sales practices and the provision of customer advice
  • Post sales servicing and customer relationship management
  • Complaints handling
  • Claims management
  • Vulnerable Customers
  • Best execution
  • Training and competence
  • Safeguarding client assets and money

We work with organisations to improve their customer facing processes and control arrangements, aligning them with their organisational strategy, commercial objectives and customer segmentation principles. This enables us to ensure that our advice facilitates sustainable compliance in a manner that enhances the customer experience and the organisation’s ability to grow its customer proposition organically. 

Our team has built conduct frameworks from inception and worked in first line of defence roles as well as in house compliance and risk and a consulting capacity. We tailor our solutions to meet the needs of each client, considering their product range, customer demographics, approach to distribution and scale of business undertaken.

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