Accordo’s Electronic Trading Services

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 Services


  • 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


  • 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
  • Assist with Blockchain Audit