With the growing dependence on information systems and evolving regulatory requirements, electronic trading operators such as Alternative Trading System (ATS) operators, Dark Pools/Alternative Liquidity Providers (ALP), High Frequency Trading (HFT) and Direct Market Access (DMA) firms are facing heightened compliance, operational and technological challenges in the United States and Europe. Regulators expect firms with electronic trading operations to conduct thorough assessments on a regular basis, establish a process to demonstrate the effectiveness of operational and technology controls and ensure compliance with regulatory requirements.
ATS/ HFT/ MTF
Market Access Rule 15c3-5
FINRA/ SEC ATS Registration
Internal Controls Assessment
Operational Risk Assessments
Annual Audit Support
Exception Report Testing & Validation
Conflicts Reviews (Manning Rule)
AML & Trade Surveillance
Business Impact Analysis
FINRA 3110 & 3310 Annual and AML Testing
Compliance/ Risk Metrics & Dashboards
Dark Pools/ ALP
Toxicity Assessments
Trade Surveillance
Liquidity Profiling
Independent Controls Review
Reg NMS/ MiFID Health Check Review
Operational Risk Assessment
Transaction Reporting
Customer Disclosures Assessment
Data Storage & Management
Information Security & Data Protection
Risk Metrics & Dashboards
DMA/ Algorithmic Trading
Market Access Rule 15c3-5
Trade Order Routing & Matching Functionality
Trade Surveillance
Record Keeping Requirements
Pre- & Post-Trade Transparency
CFTC Regulation AT Compliance
Clearing and Reporting Functionality
Regulation S-P Compliance
Entitlements and Data Protection
Risk Metrics & Dashboards
Exchanges
Consolidated Audit Trail (CAT)
Market Access Rule 15c3-5
Expert Witness & Litigation Support
Continuing Disclosures & Reporting
Regulation SCI Compliance
Operational Risk Assessments
Technology Governance
Business & Risk Controls Assessment
Trade and Regulatory Reporting
Written Supervisory Procedures
Risk Metrics & Dashboards
FIX-based Trading on Proprietary Blockchains
FIX protocol is used extensively by buy and sell-side firms, trading platforms and regulators to communicate trade information. Blockchain technology is being leveraged as a secure, reliable, and flexible platform for real-time cryptocurrency and derivatives trading.
Accordo has developed technology solutions that can assist with the review of cryptocurrency trading on blockchains to meet the new NFDFS, FATF, SEC/ FINRA or CFTC/ NFA guidelines.
Pre-Trade, Intraday and Post-Trade Analytics
Performance Metrics
Risk and Compliance Metrics
Supervisory & Compliance Reports
SAR & CTR Reports
Cybersecurity Metrics
In addition, Accordo offers the following services for blockchain-enabled trading platforms and ATS’s:
Registration of ICO’s, MSB’s or Crypto-exchanges with either FINRA or NFA.
Liaise with NYDFS, NFA and FINRA on regulatory matters
Establish a robust Compliance Program
Develop Policies and Procedures
Design and implement Internal Controls
Perform Compliance Risk Assessment
Assess and/or develop Operational Risk Framework
Data Privacy and Security Management Framework
Client Onboarding Governance
Third-Party Service Provider Reviews
Cybersecurity Controls and Risk Assessments
Business Continuity and Disaster Recovery Management
