Trade Surveillance & Market Abuse Monitor

Principal workflows

• Pre-clear: Employees request approval before they trade. The request is checked automatically against the restricted list, blackout periods, holding-period rules and open firm orders, and compliance decides on anything that is not clear-cut.
• Collect: Personal trades and holdings arrive from brokers by electronic feed or uploaded statement, and are matched to the employee and the account they declared.
• Monitor: Each personal trade is compared with pre-clearance approvals, the restricted and watch lists, and the firm's and its clients' trading in the same security, to find unapproved trades and patterns such as trading ahead of client orders.
• Review: Compliance works each exception, contacts the employee where needed, and records the outcome, from no action to escalation. The chief compliance officer approves sanctions and escalations.

Who uses it

• Chief compliance officers at investment advisers, broker-dealers and fund complexes
• Compliance analysts who review personal trading day to day
• Control room and research staff who maintain restricted and watch lists
• Employees designated as access persons who must pre-clear and report their trades
• Internal audit and examiners, who need evidence of every review

Reporting

• Pre-clearance requests by outcome, with turnaround
• Open exceptions by age, rule and analyst
• Holdings reports, transaction reports and certifications outstanding
• Trades in restricted or watch-list securities and their outcomes
• Undeclared accounts and missing broker statements
• Restricted and watch list change history for examiners

Features

• Pre-clearance: Employees request approval in a form or by email reply, with automatic checks against lists, blackouts, holding periods and open orders before compliance decides.
• Broker feeds and statements: Trades and holdings loaded from brokers' electronic feeds where they exist, and from uploaded statements where they do not.
• Restricted and watch lists: Lists maintained by the control room with effective dates, reasons and history, so every check uses the list as it stood on the trade date.
• Front-running detection: Personal trades compared with client and firm orders in the same security, with the time between them shown so a reviewer can judge the pattern.
• Explainable exceptions: Every exception states the rule, the trade, the related order or list entry and the timing, in words an examiner can follow.
• Holdings and transaction reports: Initial and annual holdings reports and quarterly transaction reports collected from access persons, with due dates and reminders.
• Annual certifications: Employees acknowledge the Code of Ethics and its amendments, and the acknowledgment is kept with the date and version.
• Holding-period and blackout rules: Minimum holding periods and blackout windows around fund trades, research or deals, configured to your Code of Ethics.
• Account declarations: Employees declare their own and household accounts, and new or closed accounts are tracked with the broker information needed for duplicate statements.
• Exception case management: Assignment, employee contact, notes, attachments and an approval step before any escalation or sanction.
• Exam-ready audit trail: Who requested, approved, reviewed or changed what, and when, for every request, trade, exception and list entry.
• Employee self-service: Employees see their own requests, approvals, reporting obligations and outstanding items, and nothing about colleagues.

Integrations

• Broker trade and holdings feeds: Electronic feeds of employee trades and holdings from brokers that provide them, and uploaded statements from those that do not.
• Order management system: Client and firm orders and executions, so personal trades can be compared with the firm's own activity.
• HR system: Employee starts, leavers, departments and role changes, so access-person status and reporting obligations stay current.
• Security master: Identifiers, issuers and related instruments, so a restriction on an issuer catches its options and other related securities.
• Research and deal systems: Events that should place a security on the watch or restricted list, sent to the control room for decision.
• Single sign-on: Employees and compliance staff sign in through your identity provider (SAML or OpenID Connect).
• Work API: Requests, exceptions and outcomes available to your data warehouse and reporting tools through the Moraph Work API.

Deployment

• Moraph cloud: Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for firms outside the US.
• Dedicated environment: A single-tenant environment for firms whose policies require isolation, scoped in the proposal.
• With a managed service: Optionally run alongside a Moraph managed service for broker feed management and platform administration.

Security and privacy

• Single sign-on: Employees and compliance staff sign in through your identity provider, so your password and multi-factor policies apply.
• Role-based access: Employees see only their own records; reviewing an exception is separate from approving a sanction.
• Confidential lists: The watch list is visible only to the roles you choose. Employees see whether a request is approved, not why a security is on a list.
• Encryption and keys: Client data is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.
• Complete audit trail: Every view, change, decision and export is logged with the person and time, and cannot be edited.
• Data residency: Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Limitations

• The Monitor flags patterns for review; it does not decide that insider trading or front-running took place. Your compliance staff make that judgment and record it.
• Monitoring covers employee personal trading under a Code of Ethics. It is not a market-wide surveillance system for client or proprietary trading on exchanges.
• Results depend on brokers providing complete and timely feeds or statements, and on employees declaring their accounts.
• Comparison with firm and client trading requires order and execution data from your order management system.
• It does not review employee communications. Email and chat surveillance needs a separate archiving and review tool.
• Gifts, entertainment, political contributions and outside business activities are not included.
• It does not file regulatory reports or make referrals to regulators; those decisions and filings are made by your firm.
• Rules are configured from your Code of Ethics; changing the Code and its rules is your firm's decision.

Next steps

Book a demonstration or a technical briefing at www.moraph.com/solutions/trade-surveillance-and-market-abuse-monitor. Purchasing routes and company information: www.moraph.com/how-to-buy.