Shortlisting Trade Surveillance Solutions - info.nice.com · While visualization and a...

S h o r t l i s t i n g T r a d e S u r v e i l l a n c e S o l u t i o n s

Anna Griem

September 2018

This authorized reprint was prepared for NICE Actimize, but the analysis

has not been changed, and the report was not sponsored by NICE Actimize.

For more information on the report, please contact Opimas

(www.opimas.com or [email protected]).

mailto:[email protected]

callto:+447397323128

https://www.youtube.com/watch?v=UUzi7VUg3VY

https://twitter.com/AnnaGriem

Copyright © 2018 Opimas LLC 1

SHORTLISTING SU RVEIL LANCE SO LUTIONS

T A B L E O F C O N T E N T S

TABLE OF CONTENTS.............................................................................................................. 1

EXECUTIVE SUMMARY ........................................................................................................... 2

INTRODUCTION ........................................................................................................................ 4

CONSIDERATIONS FOR SUCCESSFUL SELECTIONS ...................................................... 7

BUY SIDE / SELL SIDE / MARKET OPERATOR SURVEILLANCE NEEDS................. 7

HOLISTIC SURVEILLANCE .................................................................................................. 8

ARTIFICIAL INTELLIGENCE ..............................................................................................10

ADDITIONAL BUSINESS INSIGHTS ................................................................................11

COMPARING SURVEILLANCE VENDORS ........................................................................12

COMPETITION AMONGST SURVEILLANCE SOLUTIONS ........................................12

SOLUTION PROFILES .............................................................................................................18

ACA - DECRYPTEX ..............................................................................................................18

AQUIS TECHNOLOGIES – AQUIS MARKET SURVEILLANCE (AMS) ......................20

B-NEXT – CMC:ESUITE ......................................................................................................22

BAY STREET TECH ..............................................................................................................24

BEHAVOX..............................................................................................................................26

BLOOMBERG – BTCA AND BVAULT .............................................................................28

EFLOW – TZ MARKET ABUSE .........................................................................................31

FIS GLOBAL – PROTEGENT MARKET ABUSE .............................................................33

GMEX TECHNOLOGIES – FORUMDETECT ................................................................. 35

IRISIUM .................................................................................................................................. 36

ITIVITI - ANALYST ............................................................................................................... 38

KX SYSTEMS – KX FOR SURVEILLANCE ...................................................................... 39

LIQUIDMETRIX .................................................................................................................... 41

LSEG TECHNOLOGY – MILLENNIUM SURVEILLANCE ............................................ 42

NASDAQ SMARTS SURVEILLANCE................................................................................ 44

NICE ACTIMIZE – HOLISTIC SURVEILLANCE .............................................................. 45

ONEMARKETDATA – ONETICK TRADE SURVEILLANCE ........................................ 47

RIMES TECHNOLOGIES – REGFOCUS MARKET SURVEILLANCE AND MAR .... 49

SCILA – SCILA SURVEILLANCE ........................................................................................ 51

SIA - SIA EAGLE SURVEILLANCE .................................................................................... 52

SOFTWARE AG – APAMA EAGLEEYE ........................................................................... 53

THE TECHNANCIAL COMPANY - JANUS SUITE ........................................................ 55

TRADINGHUB - MARKET ABUSE SURVEILLANCE TOOL (MAST) ......................... 57

TRAPETS – INSTANTWATCH MARKET & OUTSOURCED TRADING

SURVEILLANCE .................................................................................................................... 59

TRILLIUM SURVEYOR ........................................................................................................ 61

LOOKING FORWARD ............................................................................................................ 63



E X E C U T I V E S U M M A R Y

Market abuse survei l lance requirements vary

s ignif icantly by type of market part ic ipant , appl icable

regulat ions, and the trading strategies employed. To

assist with trade survei l lance vendor select ions, t his

report detai ls the leading market survei l lance providers

– as wel l as addit ional obl igat ions they are capable of

assist ing with, including: e -communications monitor ing,

voice survei l lance, trade reconstruct ion requirements,

and best execution report ing. This report also highl ights

novel ways in which solut ions are improving alert ing

methodologies, as wel l as providing addit ional bus iness

insights for the market part ic ipants they serve . Readers

are encouraged to use this report in order to quickly

create a short l ist of the vendors suited for further

considerat ion.

Even with Nasdaq SMARTS and NICE Actimize together

owning over half of the US$284mn spend on trade and

order survei l lance software , new entrants are

aggressively vy ing for business. While the market wi l l

l ikely experience further consol idat ion in the next 12-

18 months, new solut ions are pushing the qual ity of

survei l lance forward across the board. Establ ished

solut ions have, in several cases, adopted innovative

approaches that were f i rst introduced by newcomers to

better target alerts , understand trader behavior , surface

bus iness ins ights, meet broader regulatory obl igat ions,

and automate invest igat ions .

Looking at the f ie ld of solut ions addressing t rade and

order survei l lance requirements , there are only a few

that produce alerts across both t rade and

communications data , including NICE Actimize ,

Bloomberg, and Behavox, and to a more l imited extent

Software AG, Sci la, b-next , Trapets, and I r is ium. At this

stage only NICE Actimize and Behavox produce alerts for

voice communications alongside t rade and e -

communications survei l lance .

Because the expansion of recent regulat ions , including

the Market Abuse Direct ive (MAD) and the Markets in

Financ ial Instruments Direct ive (MiFID II ) , has increased

the buy side’s t rade survei l lance and report ing

obl igat ions , several vendors have specif ical ly marketed



themselves to asset managers and hedge fun ds. ACA

Technology, RIMES Technologies , Behavox, NICE

Act imize, TradingHub, and Sybenetix (purchased by

Nasdaq SMARTS in the summer of 2017) , have al l made

a concerted push to win buy side cl ients t ransit ioning

away from rel iance on their brokers and manual

processes for market abuse and insider trading

survei l lance .

A few young f i rms l ike Aquis Survei l lance and Bay Street

Tech have posi t ioned themselves to support the

survei l lance needs of exchanges , a group currently

served predominantly by Nasdaq S MARTS and Sc i la.

Other solut ions have made inroads in specif ic

geographies. b-next has been a leader in Germany for

wel l over two decades. Neurens ic ( recently purchased by

Trading Technologies ) , Tr i l l ium, and ACA Technology

have thus far focused their att ention primari ly on the

United States. In Asia, the Technancial Company

provides competi t ion to market leader Nasdaq SMARTS .

Scandinavia is served by a host of local p layers,

including Sc i la, Trapets, and I t iv it i .

In addit ion to on-premise and hosted deployment

options, a few vendors also offer survei l lance BPO.

Trapets , Aquis , and ACA Technology both offer to stand

as the f irst l ine of defense invest igat ing alerts for

market part ic ipants who are too smal l to hi re a ful l -t ime

compl iance off icer, or who need to augment their

exist ing team.

Across the enti re t rade and order survei l lance solut ion

landscape, variety rules. When select ing a solut ion to

instal l , augment, or replace current survei l lance

approaches, f i rms wi l l need to be sure that they

appropriately short l i st the vendors best posit ioned to

meet the ir needs. In this report , Opimas provides

mapping tools and vendor profi les to help the reader

quickly ident ify the solut ions that most warrant further

invest igat ion.



I N T R O D U C T I O N

Regulat ions des igne d to prevent market abuse have

become more str ingent around the world , demanding

that cap ital markets part ic ipants proactively

demonstrate efforts to monitor and prevent behavior

putt ing the stabi l i ty of the markets and investors at r isk.

The Market Abuse Direct ive (MAD), the Markets in

Financ ial Instruments Direct ive (MiFID II ) , ESMA

Guidel ines, the Dodd Frank Act, the Hong Kong

Securit ies and Futures Ordinance, and the Singapore

Market Misconduct Regime , cumulat ively a lso require

more market part ic ipants than ever before to survei l for

market abuse and insider t rading, and appropriately

report and handle an incident when it occurs. Of course,

market part ic ipants themselves have a number of

incentives to stamp out threatening t rading conduct:

steep regulatory f ines, reputat ional damage, and

avoiding losses , to name a few.

The abi l i ty to ant ic ipate and respond to regulatory

inquir ies centered on market abuse is of paramount

importance. While 2015 represented the high point in

recent years – with f ines reaching almost US$9 bi l l ion -

market abuse f ines have become more frequent and are

hit t ing a broader swath of market part ic ipants. Many

players have gotten away, for some t ime, with

approaches to handl ing these requirements that rely on

manual , s i l oed processes. This has quickly become

insuffic ient.

Market abuse fines have become more frequent and are

hitting a much broader group of market participants.

While visual izat ion and a user -fr iendly case management

system were sel l ing points of survei l lance solut ions in

the recent past , the focus for market part ic ipants is now

fi rmly centered on reducing costs by better target ing

alerts , broadening survei l lance across s i loed channels ,

and automat ing invest igat ions . Opimas expects overal l

IT spending on survei l lance to r ise – reaching US$1.4

bi l l ion by 2021. For an in-depth analysis of th is

increased spending, expected impact on headcount, and

chal lenges associated with each stream of survei l lance,

please refer to Opimas’ Fighting Market Abuse: AI,

Behavioural , and Hol ist ic Survei l lance Approaches

report .

This report examines vendors in the t rade survei l lance

space. While most of the prof i led vendors only provide

http://www.opimas.com/research/299/detail/




trade and order monitoring, a handful also offer

communications survei l lance. In trade survei l lance , the

market share leaders, far and away, are Nasdaq SMARTS

and NICE Actimize. However, solut ions focused on very

targeted alert creation , l ike TradingHub, are quickly

winning cl ients.

F I G U R E 1 . I T S P E N D I N G O N T R A D E A N D C O M M U N I C A T I O N S S U R V E I L L A N C E I T A N D H E A D C O U N T 2 0 1 7 - 2 0 2 1

Source: Opimas Analysis

Market abuse survei l lance requirements vary

s ignif icantly by type of market part ic ipant, appl icable

regulat ions, and the t rading strategies employed. This

report detai ls the leading market survei l lance providers

– as wel l as other obl igat ions they are capa ble of

complying with, including: e -communications

monitor ing, voice survei l lance, MiFID I I trade

reconstruct ion requirements, and RTS 27 and 28 best

execution report ing. This report also highl ights

innovative ways in which solut ions are di rect ing their

alert ing methodology , as wel l as addit ional business

insights they are able to provide for the ir c l ients. For

market part ic ipants searching for pointed assistance

survei l l ing voice and/or e -communications , look for

upcoming Opimas reports on voice and e-

communications survei l lance in capital markets .

Only a handful of the profi led solut ions provide t rue e -

communications and voice survei l lance alongside market

survei l lance capabi l i t ies. NICE Act imize has led the

charge as a provider for hol ist ic survei l lance, proving

itsel f t ime and t ime again with i ts global c l ient base.

Some newcomers , l ike Behavox, are t rying to take

market share on this front – but it is early days yet.

Other players who have been on the market for some

t ime are also offer ing communications aggregation and

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

16,500

17,000

17,500

18,000

18,500

19,000

19,500

20,000

2017 2018 2019 2020 2021

IT S

pen

d (

US$ B

)

Head

cou

nt

in S

urv

eilla

nce

Total Headcount:

Sell Side, Buy Side,

Exchanges,

Regulators

IT Spend (US$ B)



more l imited monitor ing in conjunct ion with their market

survei l lance capabi l i t ies , including Software AG,

Bloomberg, Sci la, b-next , Trapets , and I r is ium. These

offerings are not yet comprehensively survei l l ing voice

alongs ide e-communicat ions, but are moving in that

di rect ion.



C O N S I D E R A T I O N S F O R S U C C E S S F U L S E L E C T I O N S

To help market part ic ipants sort through the jumble of

players act ive in cap ital markets trade survei l lance , this

report prof i les the leading and emerging solut ions designed

to detect and prevent market abuse. Product demos and

interviews with end-users have helped to val idate

functional it ies and assessments of the vendors profi led.

Before jumping to the vendor mapping and prof i les , Opimas

recommends market part ic ipants careful ly cons ider the

fol lowing:

• Does the solut ion serve my needs as a market

maker , sel l -s ide , or buy-side player?

• Which asset c lasses are covered? How are alerts

constructed?

• What other needs do I have, that a solut ion may be

able to meet? (e.g. trade reconstruct ion, e -

communications survei l lance , voice survei l lance,

best execut ion)

• How flexible is the architecture in case future

integrat ions are desi red?

In the fol lowing pages , Opimas wil l brief ly discuss some key

considerat ions to bear in mind while embarking on a

select ion, including: varied survei l lance approaches per

type of market part ic ipant , the move towards hol ist ic

survei l lance, the promise of art if ic ial intel l igence , and

addit ional business ins ights survei l lance might surface. The

f ie ld of solut ions is vast , but careful ly recogniz ing

requirements should help the reader to short l ist the vendors

most sui ted for further attention.

B U Y S I D E / S E L L S I D E / M A R K E T O P E R A T O R S U R V E I L L A N C E N E E D S

It must be underscored that it would be a mistake for a

market operator, buy-side, or sel l -s ide inst itut ion to use a

solut ion designed for another type of market part ic ipant .

Just as judging misconduct across asset c lasses with the

same algorithm is ineffect ive, so is using the same approach

for these dist inct players .



Traders are assessed dai ly , whereas asset managers are

rev iewed quarterly/monthly. The sel l s ide general ly t rades

most broadly and deeply. The buy s ide often trades broadly,

but not deeply ( long-term hold, etc ) . The sel l s ide is

regularly seen as the most compl icated , with high volumes

and varying asset c lasses and instruments. The buy s ide has

its own chal lenges due to a lack of experience taking

responsibi l i ty for survei l lance – a lso reflected in its

unwil l ingness to spend as much as the sel l s ide on

survei l lance . Insider t rading detect ion is often considered

to be the biggest survei l lance pr iori ty by the buy side, rather

than other market abuse scenarios.

Market operators ’ approaches to survei l lance also need to

be quite dist inct . They should priori t ize famil iar iz ing

themselves with survei l lance solut ions focused on equit ies

and exchange-l isted derivat ives, as this is what they wil l

need to monitor. Scalabi l i ty to handle large data volumes

and abi l i ty to conduct real-t ime monitor ing would both be

key considerat ions for exchanges or an HFT.

H O L I S T I C S U R V E I L L A N C E

Much of the market st i l l approaches survei l lance in a s i loed

manner , with separate systems creating alerts of suspicious

behaviors for each asset c lass and communication channel .

This evolution has been inevitable, given the piecemeal

expansion of regulatory requirements and the chal lenges

unique to each data set . The resul t is that compl iance teams

have often tacked together i l l - f itt ing solut ions for speedy

regulatory compl iance, or expanded legacy systems to

haphazardly analyze addit ional data sets.

Dist inct data channels require targeted approaches to

handle the unique chal lenges they present. Apply ing the

same algori thm to f ixed income as one would to equit ies, for

example , is useless. Communication channels present the ir

own di ff icult ies. The resul t i s that compl iance teams are

often overwhelmed with a f lood of alerts , nearly negat ing

the possibi l i ty for thoughtful invest ig at ion and

identi f icat ion of true posi t ives.

Select vendors l ike NICE Act imize , Bloomberg, Behavox ,

Sci la, b-next, Trapets , Software AG, Panalyt ics, and I r is ium

are posit ioning themselves to begin handl ing trade and

communication monitor ing in a hol ist ic manner , though a

system that t ruly creates alerts by combining these

disparate sources is not yet avai lable. Panalyt ics was not

profi led in this report because it does not yet offer

standalone trade survei l lance – though this is on its short-

term roadmap.



F I G U R E 2 . S U R V E I L L A N C E S Y S T E M S A R C H I T E C T U R E O V E R V I E W

Communications Archive

Trade and Order Repository

Trade and Order SurveillanceCommunications Surveillance

Documents

MetadataAnalysis

ReplayFiltering

Alert Generation

Mobile

Fixed Line

Voice Voicemail

Messenging

Electronic Communications

Email Chat apps

Social MediaVoIP Apps VoIP Apps

Meeting Minutes

Voice Voicemail

TurretsContracts Research

ComputerFiles

Internal Systems

Execution Management

AlgoTrading

Pricing/ Quotes

Order Management

External Systems

Exchange Order Books

Alternative Trading

Systems

Market Data Providers

NewsFeeds

Equit

ies

Exc

han

ge-t

raded

Deri

vat

ives

Fix

ed In

com

e

FX

OT

C D

eri

vat

ives

Trade Reconstruction

VisualizationAlert

Generation

Order Book Replay

Hollistic trade and communications surveillance

Case Management

Source: Opimas



Holist ic survei l lance can also aid in meeting MiFID I I

demands that al l pre- , at , and post-trade data, including

related text and voice communicat ions , be pul led together

for trade reconstruct ion within 72 hours of a request .

Retrievabi l i ty is key to meet ing the se new requirements ,

and this i s not a tr ivial exercise, requir ing cons istent

indexing of recorded data to transact ions, l inking together

voice, SMS, IM, Skype , and al l other required channels. This

is too often a manual , t ime- intens ive process . If offered as

a service, t rade reconstruct ion can function as more than a

sporadic task for regulatory com pl iance. Instead,

compl iance teams can also use t rade reconstruction dur ing

alert invest igat ions. Bloomberg and NICE Actimize are

highly regarded for their t rade reconstruction capabi l i t ies .

A R T I F I C I A L I N T E L L I G E N C E

The use of AI in survei l lance has the potent ial to produce

smarter alerts , improve automat ion, and reduce the

manpower needed to manage invest igat ions. If appl ied

judiciously, i t has the abi l i ty to pre-emptively identi fy

behavior indicat ive of future misconduct, before any grave

damage is incurred. We are not yet at the stage, however,

where a black-box AI solut ion gives market part ic ipants

comfort expla ining to a regulator why an alert was handled

one way or another. For now, AI i s best structured as an

overlay to c lear and defendable alert ing methodologies.

Some planned survei l lance approaches rely ing on AI alone

are currently st i l l too exotic . A rules -based engine, whi le

less exc it ing, is st i l l necessary to keep regulators at bay.

Even for solut ions employing machine learning, a common

problem exists. How can one best train a machine learning

system without the cri t ical mass of hard examples of proven

cases of market abuse? The confi rmat ion sample for true

alerts across many market abuse scenarios are very l imited,

which doesn’t lead to robust machine learning. Before

rely ing on a solut ion depending heavi ly on AI and machine

learning, f i rms should invest igate the historical data used to

train the system, and be careful about solut ions who have

constructed cases art i f ic ial ly to compensate for a lack of

true posit ives.

With the range of AI capabi l i t ies expanding, however, i t may

be wise to select a survei l lance platform bui lt with speed

and f lexibi l i ty in mind to make machine learning possible in

the future. Even i f AI i sn’ t happening yet , i t l ikely wi l l in the

future. Interest ingly , regulators have been very keen on

us ing AI and machine learning to ident ify new forms of

market abuse. There seems to be a due process issue in

holding market part ic ipants accountable for violat ions that

are not yet against the law – a subject deserving attent ion

in a separate study.



A D D I T I O N A L B U S I N E S S I N S I G H T S

While survei l lance was previously owned sole ly by the head

of compl iance , i t i s becoming a management concern in

trading as wel l . A key reason a head of trading should be

involved in choosing a solut ion is for the addit ional ins ight

a survei l lance system might provide. Survei l lance systems ,

often equipped with behavioral analyt ics , are indeed being

used to gain unexpected bus iness benef its , including:

1. Best execution analyses

2. Trader/portfol io manager performance assessment

3. Cross-sel l ing opportunity ident if icat ion

4. Employee retent ion informat ion

5. New products/ indices creat ion based on previously

unrecognized cl ient demand



C O M P A R I N G S U R V E I L L A N C E V E N D O R S

C O M P E T I T I O N A M O N G S T S U R V E I L L A N C E S O L U T I O N S

Especial ly in t rade survei l lance, the competi t ion for market

share is f ierce. As Opimas’ FinTech Spending and Innovat ion

in Capital Markets report demonstrates, IT spend for 2017

was actual ly relat ively smal l across RegTech in compar ison

to other steps in the capital markets value chain at US$6.4

bi l l ion annual ly.

Market share for the trade survei l lance software s l ice –

US$284mn total – i s intensely guarded by leaders Nasdaq

SMARTS and NICE Actimize. St i l l , new solut ion providers

have f locked to this space. The reason repeatedly c ited by

newcomers is that the incumbent providers produce poor

qual ity alerts and have inflexible architecture s. Conf idence

appears high that market part ic ip ants wi l l continue to grow

weary of incumbents that produce a f i rehose of false alerts.

But wariness over potent ial exposure to f ines due to

trust ing an untested solut ion has lengthened sales cycles

and has forced many startups to provide free proofs of

concept to prospects. The high-prof i le absorptions of young

f i rms, l ike Neurens ic and Ancoa, has made market

part ic ipants even more reluctant about rely ing on start -up

solut ions .

F I G U R E 3 . T R A D E S U R V E I L L A N C E M A R K E T

S H A R E

Nasdaq

33%

NICE Actimize

25%Scila

8%

FIS

4%

Trading Hub

4%

b-next

4%

Other

22%

Nasdaq and NICE Actimize dominate the market in trade

surveillance, accounting for over half of overall revenues...

Source: Opimas Analysis

Total Market Size TTM: US$ 284mn





We expect the market to consol idate further in the coming

12-18 months. Some of these newer solut ions are

potent ial ly overextended on impress ive , but low-paid

projects , benefi t ing mostly Tier 1 and 2 sel l -s ide

inst itut ions. There is room for these newer so lut ions to

thrive, however , and two approaches we have the most

conf idence in are :

1. Allowing market part ic ipants to layer these start-up

survei l lance solut ions on top of their exist ing alert

providers at a lower cost than tradit ional , proven

solut ions.

2. Off ic ial ly combining or partner ing with a more

establ ished player – l ike Sybenetix with Nasdaq

SMARTS.

In the face of the previously l i sted chal lenges , we expect to

see several of these new trade survei l lance f i rms making a

concerted effort to pursue these options.

The fol lowing pages contain a basic overv iew of the

solut ions act ive in t rade and order survei l lance to enable a

quick mapping of those that sui t the reader’s needs . Refer

to (

F I G U R E 4 ) to better understand the wider landscape

where these solut ions s it . F I G U R E 5 , F I G U R E 6 , and

F I G U R E 7 provide side by s ide comparisons of each

act ive solut ions funct ional it ies. For a deeper ins ight into a

part icular vendor , p lease refer to the fol lowing profi les:

• ACA - Decryptex

• Aquis Technologies – Aquis Market Survei l lance (AMS)

• b-next – CMC:eSuite

• Bay St reet Tech

• Behavox

• Bloomberg – BTCA AND BVAULT

• eflow

• FIS Global – Protegent Market Abuse

• GMEX Techno logies – ForumDetect

• I r i s ium

• ITIV ITI - Analyst

• KX Systems – Kx fo r Survei l lance

• Liquidmetr ix

• LSEG Technology – Mi l lennium Surve i l lance

• Nasdaq SMARTS

• NICE Act imize – Hol i st ic Surve i l lance

• OneMarketData – OneTick

• RIMES Technolog ies – RegFocus Market Survei l l ance

• Sci la – Sc i la Survei l l ance

• SIA - S IA EAGLE Survei l l ance

• Software AG – EagleEye

• The Technanc ia l Company - Janus Sui te

• Trad ingHub - Market Abuse Surve i l lance Tool (MAST)

• Trapets – InstantWatch Market & Outsourced Trading

Survei l l ance

• Tr i l l ium Surveyor



F I G U R E 4 . L A N D S C A P E O F S U R V E I L L A N C E S O L U T I O N P R O V I D E R S

Source : Opimas An aly s i s



F I G U R E 5 . S U R V E I L L A N C E V E N D O R S B A S I C I N F O

Source: Firms, Opimas Analysis and Estimates

AC

A C

om

plia

nc

e

Aq

uis

Te

ch

no

log

y

Ba

y S

tre

et

Te

ch

Be

ha

vo

x

Blo

om

be

rg

b-n

ex

t

efl

ow

FIS

GM

EX

Te

ch

no

log

ies

Iris

ium

Itiv

iti

Kx

Sy

ste

ms

Liq

uid

Me

trix

LS

EG

Te

ch

no

log

y

Na

sd

aq

NIC

E A

cti

miz

e

On

eM

ark

etD

ata

RIM

ES

Te

ch

no

log

ies

Sc

ila

SIA

So

ftw

are

AG

Te

ch

na

nc

ial

Tra

din

gH

ub

Tra

pe

ts

Tri

lliu

m

De

cry

pte

x

AM

S

Co

mp

lia

nce

Pla

tfo

rm

Bva

ult &

BT

CA

CM

C:e

Su

ite

TZ

Ma

rke

t A

bu

se

Pro

teg

en

t M

ark

et

Ab

use

Fo

rum

De

tect

Su

rve

illa

nce

An

aly

st

Kx fo

r

Su

rve

illa

nce

Liq

uid

Me

trix

Su

rve

illa

nce

Mille

nn

ium

Su

rve

illa

nce

SM

AR

TS

FM

C

On

eT

ick T

rad

e

Su

rve

illa

nce

Re

gF

ocu

s

Scila

Su

rve

illa

nce

EA

GL

E

Su

rve

illa

nce

Ap

am

a

Ea

gle

Eye

JA

NU

S T

rad

e

Su

rve

illa

nce

MA

ST

Insta

ntW

atc

h

Ma

rke

t

Su

rve

yo

r

2014 2018 2017 2014 2010 1989 2007 2013 2012 2010 2016 1993 2013 1996 1998 1999 2015 2016 2008 2002 2012 2013 2010 2005 2014N

ew

Yo

rk

Lo

nd

on

Mo

ntr

éa

l

Lo

nd

on

Ne

w Y

ork

He

rfo

rd, G

erm

an

y

Lo

nd

on

Ja

ckso

nville

, F

L

Lo

nd

on

Lo

nd

on

Sto

ckh

olm

Ne

wry

, N

. Ir

ela

nd

Lo

nd

on

Ma

lab

e, S

ri L

an

ka

Ne

w Y

ork

Ho

bo

ke

n, N

J

Ho

bo

ke

n, N

J

Ne

w Y

ork

Sto

ckh

olm

Mila

n

Da

rmsta

dt, G

erm

an

y

Lo

nd

on

Lo

nd

on

Sto

ckh

olm

Ne

w Y

ork

50 20 4 120 120 55 15 50 10 22 15 25 10 18 200 307 20 35 50 40 20 15 45 30 20

Europe ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ◐

North America ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

APAC ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Rest of World ● ● ● ● ● ● ● ● ● ●

Equities ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Fixed Income ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

FX ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

ETDs ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

OTC Derivatives ● ● ● ● ● ● ● ● ● ● ● ● ●

E-comms Surveillance ◐ ● ● ◐ ◐ ◐ ● ◐ ◐ ◐

Voice Surveillance ● ◐ ◐ ◐ ● ◐ ◐

Mobile Surveillance ● ◐ ◐ ◐ ● ◐

E-Comms Archiving ● ● ● ● ● ● ●

Case Mgt ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Trade Reconstruction ◐ ◐ ● ● ◐ ● ◐ ● ◐ ● ◐ ◐ ◐ ● ◐

Comms

Surveillance

Trade

Surveillance

Asset Classes

Other Functions

Regions

Company Name

Solution Names

Solution Founding Year

Headquarters

Employees for these solutions



F I G U R E 6 . S U R V E I L L A N C E V E N D O R S D E P L O Y M E N T O P T I O N S A N D C U S T O M E R B A S E


AC

A C

om

plia

nc

e

Aq

uis

Te

ch

no

log

y

Ba

y S

tre

et

Te

ch

Be

ha

vo

x

Blo

om

be

rg

b-n

ex

t

efl

ow

FIS

GM

EX

Te

ch

no

log

ies

Iris

ium

Itiv

iti

Kx

Sy

ste

ms

Liq

uid

Me

trix

LS

EG

Te

ch

no

log

y

Na

sd

aq

NIC

E A

cti

miz

e

On

eM

ark

etD

ata

RIM

ES

Te

ch

no

log

ies

Sc

ila

SIA

So

ftw

are

AG

Te

ch

na

nc

ial

Tra

din

gH

ub

Tra

pe

ts

Tri

lliu

m

On Premise ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Cloud/hosted ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Surveillance BPO ● ● ●

60 4 1000+ 80+ 50 13 3 14 216 110 10+ 9 35 30 30 50 30 14

Sell-side - Tier I ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Sell-Side - Tier II & III ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Buy-side - Tier I ● ● ● ● ● ● ● ● ● ● ●

Buy-side - Tier II ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Exchanges ● ● ● ● ● ● ● ● ● ● ●

Regulators ● ● ● ● ● ● ● ● ● ● ● ●

A2

X, U

BS

UK

OT

F, U

S A

TS

, C

an

ad

a IB

& e

xch

an

ge

Ma

rsh

all W

ace

, T

P IC

AP

, A

rro

wg

rass

Bö

rse

Stu

ttg

art

, C

om

me

rzb

an

k, IT

G,

Sa

nta

nd

er,

So

cG

en

, U

BS

Ka

me

s C

ap

ita

l, U

niC

red

it, S

ing

ap

ore

Mo

ne

tary

Au

tho

rity

AL

TX

Ug

an

da

, IC

DX

, H

an

oi S

tock E

xch

an

ge

,

CA

SE

, S

EE

D C

om

mo

ditie

s E

xch

an

ge

Asia

Pa

cific

Ex, C

ow

en

, E

ne

rgie

Ste

ierm

ark

,

Ce

nko

s, B

itfin

ex

Ba

nk o

f A

me

rica

Me

rrill L

yn

ch

, A

SIC

,

Sta

nd

ard

Ch

art

ere

d B

an

k, C

SA

, IE

X

Ma

cq

ua

rie

LS

EG

BIV

A, G

em

ini, H

KE

X, S

IX S

wis

s, S

tatk

raft,

AC

ER

, IIR

OC

BN

P P

ari

ba

s, H

SB

C, JP

MC

, M

izu

ho

Se

cu

ritie

s

Cre

dit S

uis

se

La

rge

pe

nsio

n fu

nd

LS

E, N

YS

E, D

eu

tsch

e B

örs

e, A

the

ns S

E,

Iris

h S

E

LS

EG

KG

I O

ng

Ca

pita

l, C

iti, B

AM

L, S

ocG

en

UB

S, In

ve

sco

, A

be

rde

en

Se

yd

ler

Ba

nk, N

GM

, N

DX

, D

ha

ka

SE

Lim

e B

roke

rag

e, A

pe

x C

lea

rin

g, A

dva

nta

ge

Fu

ture

s, G

elb

er

Gro

up

Representative Clients

Deployment

Options

Client Type

Nr of Installs

Company Name



F I G U R E 7 . S U R V E I L L A N C E V E N D O R S F U N C T I O N A L I T Y O V E R V I E W


AC

A C

om

plia

nc

e

Aq

uis

Te

ch

no

log

y

Ba

y S

tre

et

Te

ch

Be

ha

vo

x

Blo

om

be

rg

b-n

ex

t

efl

ow

FIS

GM

EX

Te

ch

no

log

ies

Iris

ium

Itiv

iti

Kx

Sy

ste

ms

Liq

uid

Me

trix

LS

EG

Te

ch

no

log

y

Na

sd

aq

NIC

E A

cti

miz

e

On

eM

ark

etD

ata

RIM

ES

Te

ch

no

log

ies

Sc

ila

SIA

So

ftw

are

AG

Te

ch

na

nc

ial

Tra

din

gH

ub

Tra

pe

ts

Tri

lliu

m

Smart Alerts ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Behavioral Analytics ● ● ● ● ● ● ● ● ◐ ● ● ● ● ●

Relationship Mapping ● ● ● ◐ ● ● ● ◐

AI / ML ● ● ● ● ● ● ● ● ● ◐ ● ◐ ●

Natural Language Proc ● ● ● ◐ ◐

Sentiment Analysis ● ● ● ● ● ●

OMS/EMS ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Market Data Feeds ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Evaluated Prices ● ● ● ● ● ● ● ◐ ● ● ● ● ●

Corporate Actions ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Market News ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Alert Customization ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

APIs, ease of integration ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Ability to extract data ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Best Execution ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Regulatory Reporting ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●

Performance ● ● ● ● ● ● ● ●

Employee Retention ● ●

Cross-selling ●

Advanced

Analytics

Tech Flexibility

Beyond

Surveillance

Data Sources

Ingested

Company Name



S O L U T I O N P R O F I L E S

A C A - D E C R Y P T E X

Decryptex market survei l lance has been part of ACA

Compliance Group’s (ACA) RegTech solut ion suite s ince

2016. With the recent acquisit ion of Cordium, ACA serv ices

over 4000 cl ients global ly . Headquartered in New York City,

the solut ion is used g lobal ly , but most c l ients currently run

their compl iance programs in the United States, and many

have non-US subsidiar ies. When purchased by ACA,

Decryptex was integrated with ACA NorthPoint ’s h istorical

infrastructure. The solut ion is complemented by othe r

compl iance consult ing and outsourc ing services run by

ACA’s global team of ex regulators, including emai l rev iew.

Decryptex automates the survei l lance of insider trading,

market manipulat ion and fai rness in deal ing. MAR scenarios

include but not l imited to: spoof ing, layering, cross ing,

momentum ignit ion and other that cross with insider deal ing

and market abuse. New algorithms cover fai rness in deal ing

which represents best execution and al location equal ity.

Decryptex has a unique approach to MNPI monit or ing and

tracks buy side f i rms meetings. The solut ion covers f i rms

trading equit ies, derivat ives , currencies, and f ixed income .

Most of Decryptex’ 60 cl ients are hedge funds or asset

managers , and 2/3 trade equit ies in some form. Decryptex

has not yet pos it ioned i tsel f to address survei l lance of

i l l iquid securit ies nor to meet the needs of HFTs. 90% of

users deploy the solut ion in the cloud and 10% run i t on

premise. 10% of c l ients also use ACA’s ful ly outsourced

trade survei l lance serv ice – a l lowing ACA to act as f i rst l ine

compl iance off icers. Decis ions and responsibi l i ty to submit

reports to regulators st i l l rest with the cl ient , not ACA.

Decryptex’s prof i l ing of c l ients ’ t rading strategies (average

holding per iod, t ransaction s ize, avera ge volat i l i ty for each

speci f ic securi ty, etc ) , is key to false posit ive reduct ion. Its

proprietary T+1 alert ing algori thms consider more than

trading and posit ion act ivity. Decryptex drop grabs the

trade data in a bulk f i le at the end of the day, from the OMS,

and then augments i t with pr ic ing feeds , market data ,

corporate act ions, and cl ient speci f ic information l ike

meeting calendars. Because the algori thm is conf igured for

each cl ient , the parameters producing alerts vary with each

instal lat ion. Deployment typical ly takes 2 months, mostly



spent c leaning data , and then tweaking the alert ing

speci f icat ions to sat isfy the end user.

F I G U R E 8 . A C A D E C R Y P T E X T R A D E D A S H B O A R D

Decryptex’ case management is capable of ingest ing

relevant e-comms as wel l as having attachments added to

alerts be ing invest igated. Dist inct f rom other solut ions,

Decryptex does not score the r iskiness of created alerts nor

does i t provide market replay. In the future, ACA is

consider ing expanding Decryptex to i ngest communications

and provide archiving of al l survei l led data. Decryptex is

wel l suited for buy side inst itut ions who do not require real -

t ime survei l lance and whose pr imary concern is American

regulat ions.



A Q U I S T E C H N O L O G I E S – A Q U I S M A R K E T S U R V E I L L A N C E ( A M S )

London headquartered Aquis Technologies , the

technologies divis ion of Aquis Exchange PLC, introduced

Aquis Market Survei l lance (AMS) to the market in 2017.

While the overarching goal of Aquis Technology is to offer

al l of the tools required to r un a market place such as an

MTF from scratch, AMS is also sold as a standalone solut ion.

Aquis Exchange also bui l t AMS for its own operation as an

MTF – suggesting an addit ional incent ive to keep the

service compl iant and running on best pract ices.

AMS’ rules-engine is preconf igured to keep i ts c l ients up -

to-date with regulat ions – both for survei l lance of longer

term manipulat ion l ike ins ider t rading and pump and dump,

and for shorter term scenar ios l ike layering. Users are

equipped with a p arser to bui ld and edit parameters with

immediate effect , and can back test alerts with historical

data. AMS generates alerts in real -t ime and T+1 where

appropriate, and the system creates t imestamps and unique

IDs for further analysis and report ing.

The technology special izes in h igh-volume and real -t ime

transactions. Scalabi l i ty is a key considerat ion in the des ign

– tested through the ful l rules l ibrary at 170 mil l ion

messages per second sustained. AMS is avai lable hosted or

on premise - accessible v ia a customizable web-based

portal . Typical deployment and alert customizat ion takes 3

calendar months. Aquis also offers various levels of

managed serv ices, providing the f irst l ine of defence for

c l ients who want to outsource init ial alert invest igat ion s in

an auditable manner. Because responsibi l i ty cannot be

outsourced, the decis ion to submit a report to regulators is

always made by the cl ient , not Aquis.

F I G U R E 9 . A Q U I S T E C H N O L O G I E S

S U R V E I L L A N C E D A S H B O A R D

Al l act ivity withi n AMS’ case management system is

auditable and structured to reflect c l ients ’ desi red rules and



permiss ioning. The invest igat ion dashboards al low

compl iance off icers to zoom in down to the microsecond

level and to part icular points of interest al lowing

visual isat ion of f irm events overlaid on top of the wider

market picture. Users can also configure reports to

understand alerts over t ime. Alerts are currently explained

via pop-up, which is a bit awkward to navigate , but this

feature is currently be ing changed.

Aquis has both bite s ize and ambit ious future plans for AMS.

Minor intended improvements to user experience and

eff ic iency include: t ightening workflow to help users

understand alerts quickly, presenting T+1 and real -t ime

alerts more dist inct ly , and expanding the l ibrary of reports

that can be generated. Longer term Aquis plans to leverage

monitored data to, for example, help users better

understand their customers and support KYC efforts. Aquis

is also consider ing moving into survei l lance of unstruct ured

communications data v ia a partnership.

Aquis ’ AMS is a powerful , targeted solut ion that could

certa inly compete with the l ikes of Nasdaq SMARTS,

Mil lennium IT, and Sc i la for the business of market makers.

Although only around for 1 year now, it has s igned on a

diverse c l ient group who seem pleased by the solut ion’s

rel iabi l i ty , f lexibi l i ty , and strength.



B - N E X T – C M C : E S U I T E

A leader in Germany for wel l over two decades, b-next i s

headquartered in Herford, Germany. b -next ’s CMC:eSuite i s

an integrated, modular compl iance platform that offers

f inancial inst i tut ions a means of detecting potential

attempts at market manipulat ion. Over 120 scenarios are

avai lable out-of-the-box, with custom scenarios to be

determined by cl ients ’ needs. b-next modules include:

CMC:Market Abuse , CMC:Global Control Room ,

CMC:Confl icts of Interest , CMC:Insider Compl iance ,

CMC:FX Benchmarking, CMC:Energy, and CMC:Blockchain

Survei l lance.

Modules also cover best execution, price deviat ion

detect ion, benchmark monitor ing, cross -market and cross -

asset monitoring. While mostly serving the sel l -s ide and a

few regulators, b-next has also gained tract ion with the

MAR and MiFID I I affected members of the buy -side, as wel l

as energy and commodit ies trading f i rms.

b-next provides mult i -asset survei l lance, with some cl ients

contributing their own data to best analyze OTC. Cl ients are

able to further hone a lerts and thresholds to their comfort

level . While market data agnostic , b -next does have a

partnership with Thomson Reuters to s impl i fy access. b-

next is also set up to be conf igurable with any OMS .

F I G U R E 1 0 . b - n e x t C A S E M A N A G E M E N T

D A S H B O A R D

About 40% of b-next’s c l ient base deploys the survei l lance

solut ion ei ther hosted on Thomson Reuters’ Elektron or

elsewhere, with the remaining 60% of c l ient s relying on an

on-premise instal lat ion . More new sales are opting for a

hosted solut ion. The b-next case management view was

bui lt to sat isfy compl iance off icers ’ needs – with

visual izat ions and sort ing possible by alert and cl ient type.

b-next has t imestamp connect ions that t ie t rade and order

data and ingested voice recordings and transcript ions from

its partner Verint within its CMC: Dig ital Communications



Analyt ics module. Verint helps b -next to enable voice

survei l lance analys is with near t ime technology , including

the t ranscript ion of ca l ls in 40 languages . b-next provides

21 preconfigured scenar ios for c l ients requir ing analysis of

voice f i les.

b-next’s roadmap centers heavi ly on robust MAR and MiFID

I I best execution compl iance , as wel l as preparat ion in case

of future regulatory demands for real- t ime or near-t ime

monitor ing of market abuse . b-next has a lso agreed to

partner with Catelas to offer jo int market and e-

communications survei l lance in the future.



B A Y S T R E E T T E C H

Bay Street Tech is a young Canadian outf it , founded with

the goal of better serving the capital markets’ t rade

survei l lance needs. Bay Street began in 2017 by targeting

the needs of smal l market operators who were dissat isf ied

with other solut ions’ struggle to cope with high -volume,

real-t ime survei l lance. S ince thes e earl iest days, the

offering has expanded to also serve the monitor ing needs of

the buy and sel l s ide across equit ies, derivat ives, f ixed

income, FX, and energy & commodit ies , both in real t ime and

T+1.

Deployed as a web appl icat ion, c l ients can choose to run

Bay Street on the cloud, hosted or on premise. The platform

is a standout for usabi l i ty – with a whol ly integrated and

auditable case management system. The workflow is

intuit ive and thoughtful ly eff ic ient , with options to digest

alert descr ipt ions in text , graphic , or tabular v iews. The

platform also makes i t easy for a permiss ioned user to add

new “watch l i sts” , e .g. new corporate act ions feeds to be

considered.

Bay Street includes a wide range of analyt ical tools to help

users invest igate alerts as wel l as discover key market abuse

indicators on their own to feed back into their alert ing

methodology. A modular table view of al l ingested data also

al lows users to play with col lected informat ion through drag

and drop funct ional ity to create reports, an d to surface

addit ional business insights, including best execution and

operations monitor ing. Users are also able to bui ld

interact ive visual izat ions of their analyses within the

platform, which other users can dr i l l into for further

considerat ion.

F I G U R E 1 1 . B A Y S T R E E T T R A D E S U R V E I L L A N C E

D A S H B O A R D

Alerts are tai lor made per asset c lass, capable of monitoring

cross market and cross asset c lass where appropriate.

Cl ients can further hone alerts and discover alternative

outcomes by using Bay Street ’s proprietary back test ing

engine. This homegrown tool runs cons istently at



approximately 2 mil l ion transactions per second – though it

can more than tr ip le this speed.

Bay Street is a new company with impressive data

processing power, a very careful ly cons idered workflow,

and a breadth of f lexible analyt ical tools . Of course , i t i s

st i l l early days for this solut ion, but thus far feedback from

its f irst instal lat ions has been posi t ive.



B E H A V O X

A 2014 entrant headquartered in London, Behavox offers a

“people analyt ics” enterprise platform that integrates

transaction, communicat ion, voice, and CRM data into a

unif ied enterpr ise grade data lake deployed ons ite or v ia the

cloud (e.g. Amazon Web Serv ices, Google Cloud Platform, or

Microsoft Azure) . Proprietary Behavox machine learning ,

natural language process ing, and phonetic analysis run to

identi fy capital markets misconduct , insider threats , and to

surface other employee and customer ins ights. Beh avox has

received signi f icant attention for i ts MAR compl iance use

case, but is posi t ioning itsel f to offer a broader array of

services spanning research unbundl ing, t rade

reconstruct ion, e-discovery , and the surfacing of business

insights from CRM and com municat ions data.

While the t rade and transact ion survei l lance feature is st i l l

quite new, only added to the Behavox suite late in 2017,

Behavox has made a name for i tsel f quickly for e -comms and

voice analysis . Behavox scores communicat ions on

trust/closeness ( indicators include: laughter, emot icons,

spel l ing errors, response t ime, etc . ) and business crit ical ity

to determine the r isk iness of relat ionships . Cl ients seem

part icularly drawn to Behavox’ visual izat ion capabi l i t ies,

including relat ionship maps and word clouds, as wel l as the

abi l i ty to assist with trade reconstruction requirements.

F I G U R E 1 2 . B E H A V O X R E L A T I O N S H I P M A P

Behavox has preconfigured over 150 scenarios looking for

misconduct (many addressing MAR, some for internal

threats l ike sexual harassment) . To analyze voice

interact ions Behavox developed a phonet ic keyword search,

based on 16 years of North America and Europe

enforcement communicat ions . This range of scenarios grows

with every c l ient engagement , and i s coupled with detection

of emotions in conversations that contribute to the r isk

scoring (questions, whispering, debate, anger, interruptions,

p itch, tone, intonat ion).



Fol lowing early attention from a few large hedge funds,

Behavox has also received heav y interest f rom the sel l -s ide ,

even secur ing a major investment from Cit igroup in 2017.

While relat ively new to the market and relat ively untested,

Behavox is posi t ioning itsel f to be a hol ist ic people analyt ics

solut ion that aggregates al l communications data into one

integrated solut ion, correlates those communicat ions to

other data types , and produces immediate act ionable

insights for the ir c l ients. This is d ist inct f rom incumbents

who provide a hol ist ic solut ion via acquisi t ions of once

dist inct solut ions or who sel l e lements of an integrated

solut ion without vert ical integrat ion.

Behavox cla ims it is bui ld ing the f i rst behavioural operat ing

system with an eventual focus extending wel l past

compl iance into areas l ike productiv ity, culture, and

revenue generat ion.



B L O O M B E R G – B T C A A N D B V A U L T

Founded in 1981 and headquartered in New York City,

Bloomberg’s pervasive presence in capital markets

(325,000+ terminals worldwide ) also extends to market and

communication monitoring and archiving.

BLOOMBERG TRAN SACTIO N COST ANALYSI S ( BTC A)

In BTCA, c l ients receive t ransaction cost analys is (TCA),

best execution analys is ( including report ing capabi l i t ies for

MiFID I I RTS 27 & 28) , and survei l lance capabi l i t ies for the

prevention and detect ion of market misconduct. The market

survei l lance offering highl ights outl iers and helps determine

underlying causes. Designed to meet general survei l lance

and report ing requirements for the broadest community

r ight out of the gate, BTCA is a mult i -asset solut ion

addressing equit ies, f ixed income, forex, and futures. Trade

data, as wel l as Bloomberg market data and news feeds with

bas ic sent iment analys is , are included in the offering.

BTCA’s case management system faci l i tates appropriate

escalat ion procedures and assignment of exceptions -

evidenc ing efforts made to comply with regulat ions in an

auditable form. For Bloomberg users, i t takes only about 1

month to deploy market survei l lance capabi l i t ies. While

speci f ics vary by requirements, alert configurat ion typical ly

includes back test ing of about one year of the cl ient ’s

historical data. Users have access to a 24/6 Bloomberg

support l ine in case of issues.

F I G U R E 1 3 . B L O O M B E R G B T C A T R A D E


Bloomberg’s roadmap for BTCA direct ly responds to c l ient

requests , and is priori t iz ing development of OTC der ivat ives

survei l lance. With industry -wide demand also present for

combined analys is and v iew of unstructured

communications , as wel l as t rade and order data, Bloomberg

is exploring hol ist ic invest igat ion capabi l i t ies.



BLOOMBERG VAU LT (BVA ULT)

Bloomberg provides communications archiv ing and

survei l lance for:

• Bloomberg data, corporate emai ls , ins tant messaging

apps , soc ial media, f i les,

• Voice t ranscripts and recordings - Red Box partner,

but compatible with others )

• Trade data - Bloomberg t rading systems and data

exports from 3 r d part ies through Bloomberg’s

Connectivity and Integrat ion Solut ion (CIS)

The BVault archive, is wel l regarded for regulatory

compl iance. Though equipped with Bayesian search

capabi l i t ies, most c l ients rely on the lexicon and keyword

search functional it ies . For communication survei l lance,

BVault suppl ies 40+ customizable pol ic ies , as wel l as real -

t ime enterpr ise rule violat ion monitoring. Its intuit ive

interface is accessible through a w eb appl icat ion for

dispersed reviewers . With an audit trai l and report ing

capabi l i t ies, users also have the abi l i ty route alerts by type

and to manage the review process hierarchy.

In BVault ’s trade reconstruction service, communication

data is immediately searched for and tagged with

transactions , and then exported in the required format .

While c l ients express sat isfact ion with the result in g report

and eff ic iencies obtained, i t i s often judged to be too

expensive for use in dai ly invest igat ions of suspicious

alerts.

F I G U R E 1 4 . B V A U L T C O M M U N I C A T I O N S

M O N I T O R I N G D A S H B O A R D

While many compet itors in the survei l lance space offer

more niche solut ions, Bloomberg begins by serving the

needs of the general populat ion, and then adds speci f ic



requirements for subpopulat ions. This serv ice model

enables the quick and easy deployment of survei l l ance and

archiving capabi l i t ies for general needs. For f inanc ial

inst itut ions already using the Bloomberg Terminal ,

communications survei l lance is included with their Terminal

subscript ion. That, along with the quick deployment , has led

a number of f inancial inst itut ions to select BVault for MAR

and MiFID II compl iance as wel l .



E F L O W – T Z M A R K E T A B U S E

Founded in London in 2004, ef low began by offer ing

straight-through process ing services to investment banks.

Fol lowing ini t ial success in this area, ef low introduced the

TZ regtech suite in 2007. This offer ing provides several

services in addit ion to trade survei l lance for the prevention

of market abuse, including TCA, best execut ion, and

transaction report ing capabi l i t ies completed via LSEG and

Euronext partnerships . While heavi ly focused on the buy

and sel l s ide in Europe, ef low’s 50+ TZ Market Abuse

instal lat ions include a handful of c l ients in the United States

and Asia Pacif ic .

Prior to MAD and MiFID I I , ef low’s c l ient base consisted

mostly of sel l s ide inst itut ions, roughly spl it between

hosted, on premise deployments and white label

partnerships. Since these regulat ions have come into force

new sales have been dominated by the buy s ide and HFTs,

with 95% opting for the hosted offering. Eflow’s scalabi l i ty

is underscored by the variety in its c l ients’ dai ly t rading

volumes – s tart ing from as few as 100 but robust enough to

handle mil l ions. The TZ platform is priced by volume, making

it appeal ing to smal ler buy side f irms with new survei l lance

obl igat ions .

F I G U R E 1 5 . E F L O W T R A D E S U R V E I L L A N C E

D A S H B O A R D

The solut ion is except ion dr iven with custom parameters,

monitor ing for 50+ preconf igured scenarios across al l asset

classes. Users benefit from the solut ion’s bui l t - in

integrat ion with market news and a host of market data

vendors thanks to exist ing eflow partnerships. The system’s

STP foundat ion has the abi l i ty to ingest mult ip le data

sources (currently ingest ing from 240 market data sources)

at one t ime, this also enables a reduct ion in the t ime to

deployment. General ly speaking, ef low’s c l ients move fr om

a free proof of concept to ful l deployment , back test ing the

system with 3 months of historical data, in two months.

TZ also al lows for unl imited users with defined access at no

extra cost and comes with an auditable case management



system, with assignable workflow, and storage for up to 7

years. Users can attach f i les, URLs, and news stories to

relevant cases, and can also ingest e -comms and voice

recording f i les . TZ Market Abuse users can employ keyword

analysis on ingested email and chat. The case ma nagement

system includes interact ive, customizable, and exportable

reports, often set up for part icular regulatory requirements.

Eflow also runs t rade reconstruct ion reports upon request

from a c l ient. While most trade reconstruction reports take

only minutes to run, when accessing archived data the

process may take a few hours.

Eflow’s cost effect ive solut ion has recently seen espec ial ly

strong growth with smal ler buy side f i rms driven by MAD

and MiFID I I ’ s requirements. The new release of TZ Market

Abuse promises improvements to the user experience, data

mining capabi l i t ies, and grouping of alerts by various

categor ies. The updates should enable the user to more

readi ly surface business insights, inc luding about

counterpart ies.



F I S G L O B A L – P R O T E G E N T M A R K E T A B U S E

The FIS Protegent sui te supports f inancial inst itut ions as

they automate compl iance processes across customer

onboarding, employee trading and code of ethics , sales

suitabi l i ty test ing, social media act iv ity review, and market

abuse detect ion. Though FIS is headquartered in

Jacksonvi l le , Flor ida, Protegent was a lready on the market

as a SunGard product in 2013. FIS Protegent Market Abuse

posi t ions itself to serve the sel l s ide and the buy side as a

cross asset c lass and cross jur isdict ional surv ei l lance

solut ion. Al though it covers al l asset c lasses , c l ient need has

driven strongest development of equit ies , futures and

options survei l lance thus far. Cl ients who use Protegent to

monitor f ixed income require extra configurat ion with the

provided market data to gain confidence in alert qual ity.

Protegent Market Abuse gives users access to view, edit and

add to the out-of-the-box rules l ibrary provided upon

deployment . By monitoring changes in market and

part ic ipant act ivity, the solut ion continuously tr ies to

improve alert algori thms and reduce fa lse pos it ives.

Protegent analyzes an array of sources when surfac ing an

alert , including: t rade and order data ( ICE, CME, LSE G,

NYSE, ASX) , c l ient data, Thomson Reuters market data, and

market news. Most c l ients run a hosted solut ion, though

some holdouts st i l l require an on-premise service.

Responding to c l ient requests, F IS has also begun aiding in

pul l ing data from Protegent for MiFID I I trade

reconstruct ion requirements.

F I G U R E 1 6 . F I S P R O T E G E N T F R O N T R U N N I N G

V I S U A L I Z A T I O N

Protegent ’s case management al lows for the establ ishment

of a user hierarchy and roles, and tracks a l l invest igat ive

act ivit ies in an auditable manner. Alert visual izat ions,

market replay , and bulk t racking and clos ing of grouped

alerts aid in speeding up compl iance off icers ’ inspections.

The platform also al lows for the attachment of related

f i les/evidence to part icular cases, me aning that al l



documents related to a part icular case can be kept within

the same system and reports can be more easi ly created.

FIS’ broad coverage across asset c lasses t icks the box for

compl iance, but future plans for the Protegent Market

Abuse offering include improving the depth of i ts

survei l lance qual i ty for each individual asset c lass. F IS also

wants to del iver t rue cross asset and cross venue

manipulat ion detect ion, where alerts are currently produced

from more si loed sources. The roadmap include s providing

users with v iews of individual and f i rm level act ivity,

al lowing greater overv iew of susp icious relat ionships. The

push for hol ist ic t rade data and communicat ions data

survei l lance is also not lost on FIS, who is consider ing

bui ld ing out this functional ity via partnerships. Protegent

Market Abuse offers expansive asset c lass coverage for

market part ic ipants , though wil l need to deepen analysis in

order to remain competit ive.



G M E X T E C H N O L O G I E S – F O R U M D E T E C T

London based GMEX Technologies (GMEX) del ivers a mult i -

asset ‘exchange-in-a-box’ offering, including a market

survei l lance solut ion designed for exchanges , brokers,

proprietary trading desks and other market part ic ipants to

ensure compl iance with market rules, regulat ions , and

internal market survei l lance pol ic ies. While GMEX has

notably gained tract ion with young exchanges in emerging

markets, ForumDetect has also been adopted by new

exchanges and market makers global ly , including in the

United States.

ForumDetect comes with preconfigured al erts to surface

potent ial market manipulat ion, t rading act ivi ty issues,

benchmark alerts , and volat i l i ty c ircuit breaker alerts. U sing

the ‘Esper’ OpenSource Event Programming Language to

define thresholds and alerts , ForumDetect is a real - t ime and

T+1 survei l lance system that can be deployed local ly or as

a hosted solut ion. Del ivered via a browser based

appl icat ion, the system has been constructed to monitor for

cross-market and cross-asset c lass scenar ios .

GMEX’ ForumDetect includes case management

functional it ies to handle the process of invest igat ing,

referr ing, escalat ing , and report ing of suspected market

abuse. The system includes a display of surfaced alerts

requir ing further scrutiny by a compl iance off icer, as wel l as

tools enabl ing alert inves t igat ion including market replay

capabi l i t ies and reports for post -event rev iews.

F I G U R E 1 7 . G M E X F O R U M D E T E C T V I S U A L

S U R V E I L L A N C E



I R I S I U M

Ir is ium Ltd, a subsidiary of KRM22 PLC and Cinnober

Financ ial Technology, provides cross-asset trade

survei l lance systems to sel l -s ide, buy-side , exchanges,

regulators and crypto f irms . I r is ium's market survei l lance

solut ion helps detect the r isk of market manipulat ion and

insider trading pract ices . It has been designed to comply

with EU, US and Far Eastern market abuse regulat ions .

Ir is ium’s precursor Ancoa Software, b irthed in 2010, was

acquired by Cinnober Financ ial Technology in May 2017. In

June 2018, Cinnober sold a 60% stake in I r is ium to KRM22

plc , an investment f i rm focused on cap ita l markets r isk

management . KRM22 intends to develop a r isk management

platform, incorporating I r is ium Survei l lance. The rebranding

to I r is ium was accompanied by a strategic review of the

architecture, a restructuring of the solut ion’s technology

team by hi r ing compl iance subject matter experts, and the

implementation of a new roadmap. I r is ium today looks quite

a bit di fferent from Ancoa.

In addit ion to real -t ime analysis of transact ional data,

Ir is ium incorporates news data feeds for the detect ion of

insider t rading. The solut ion also includes b est execution

analyt ics to meet MiFID I I obl igat ions. I r i s ium can ingest and

store a c l ient ’s electronic and voice communications to

provide a more hol ist ic v iew of t rading behaviour , with

lexicon-based pol ic ies able to generate basic alerts for text

communications. The solut ion includes an intuit ive case

workflow management system, offering event replay

visual izat ions, order book replay , and the back test ing

against histor ic data . Al l act ivi ty within the pla tform creates

an untampered audit t ra i l .

F I G U R E 1 8 . I R I S I U M T R A D E V I E W

Ir is ium is launching in Q4 2018 its next generation of market

survei l lance systems , aiming to bring substantial technical

and functional improvements. Vert ical scalabi l i ty , real -t ime

processing, automation through use of AI / machine



learning, and user experience through careful ly des igned

alert visual isat ions are top of Ir is ium’s agenda .

In the last 6 months I r is ium has won new 3 -5 year l icens ing

deals on the back of improvements already made post the

Cinnober acquisit ion. With a new brand, larger shareholder

base, addit ional subject matter experts , and a reinvigorated

platform, I r is ium is much better posit ioned than it was just

one or two years ago.



I T I V I T I - A N A L Y S T

It iv it i Analyst i s a cross asset c lass survei l lance solut ion

offered by It iv it i , formed by the union of Orc Group and

CameronTec Group in 2016 and headquartered in Stockholm

Sweden. With I t iv it i ’ s March 2018 merger with ULLINK, the

f i rm has more soundly posi t ioned itself as a ful l service

trading technology and infrastructure provider. It iv i t i

Analyst conducts real -t ime monitoring of algorithmic

trading act iv ity , including the capabi l i ty to generate ki l l

s ignals . It iv it i Analyst also provi des market abuse detection,

MiFID I I best execut ion analys is and report ing, market

maker compl iance monitor ing, and Transact ion Cost

Analysis (TCA).

The solut ion can be run either hosted or on premise. I t iv it i

Analyst has a handful of smal ler investment b anks and

proprietary t rading f i rms as c l ients, but is hoping to win

more business on the back of extending their modular

solut ion to cover more execut ion analyt ics and business

intel l igence. The f i rst module, It iv it i Analyst MAR, was

released in 2016 due to the Market Abuse Regulat ion

coming into appl icat ion. Alerts are preconfigured, but both

detect ion and scoring can be tweaked to best f i t a c l ient.

Dur ing deployment the tool bui lds up a repository of

historical c l ient data used for tuning to reduce the n umber

of false posit ives and ensure the algorithm is a sounder f it .

It iv it i Analyst provides case management capabi l i t ies with

an audit tra i l in case of regulatory scrut iny. Visual izat ions

and market replay functional i t ies are designed to help the

user make sense of the alerts created. At this stage there is

no integrat ion with communication survei l lance solut ions.

F I G U R E 1 9 . I T I V I T I A N A L Y S T T R A D E




K X S Y S T E M S – K X F O R S U R V E I L L A N C E

Kx Systems, headquartered in Northern Ireland alongside

parent company First Derivat ives, leverages its algorithmic

trading infrastructure to al low users to monitor for market

abuse scenar ios across asset c lasses and markets , both on

premise and hosted. Kx Systems’ survei l lance offering, Kx

for Survei l lance, serves mostly exchanges and large banks,

as wel l as some regulators, to provide historical , T+1, and

real-t ime trade and order survei l lance. Kx cl ients seem

part icularly sat isf ied with Kx’ coverage of f ix ed income and

fore ign exchange. While st i l l relat ively new to the market in

compar ison to market share leaders Nasdaq SMARTS and

NICE Actimize, Kx has impress ively raised its profi le and

grown its c l ient base in recent years.

Customers can cal ibrate 40+ preconfigured market abuse

parameters in real t ime , with desi red permission sett ings,

escalat ions, and back test ing possible within the ful ly

auditable case rev iew system. Typical ly , users choose to

digest alerts by f i l ter ing for the t rader involved, the

category of alert , the t imestamping, and/or the record of

raw transactions. Drag and drop columns a id in compl iance

officers ’ analys is , and users can bui ld dashboards and

visual izat ions as they see f it . The f lexibi l i ty of Kx’ historical

database and replay e ngine further help invest igat ions.

Kx for Survei l lance does not come standard with addit ional

market data, though partnerships with Thomson Reuters and

Bloomberg a id in providing what a c l ient might l ike to

include in analyses. Bespoke connectors are a lso often bui l t

to c l ients’ proprietary databases. While not currently

analyzing voice and communications, Kx has referenceable

success stories conf iguring with e -comms and voice

monitor ing providers – including mapping voice metadata to

trade data upon a c l ient’s request.

F I G U R E 2 0 . K X F R O N T R U N N I N G A L E R T

V I S U A L I Z A T I O N

Post a standard market survei l lance deployment , Kx has met

several custom requirements, including: creating c l ient -

speci f ic alerts , best execut ion report ing for RTS 27 & 28,

preparing t ransaction reports for MiFID I I ARMS, TCA, and



alerts for benchmark manipulat ion. Kx for Survei l lance is

considered to be amongst the most f lexible solut ions – a

draw for c l ients confident enough to accept the

responsibi l i ty this accompanies – and a potential drawback

for the less technical ly sophist icated. The solut ion is not

overengineered, which is part icularly appeal ing for c l ients

who would not be sat isf ied with a plug and p lay solut ion.



L I Q U I D M E T R I X

LiquidMetrix, based in London, del ivers a suite of

compl iance monitoring solut ions including TCA, best

execution, venue stat ist ics ( including systematic

internal izer determination) , and survei l lance for the

prevention of market abuse.

Target ing sel l - and buy-side inst itut ions, L iquidMetrix

Survei l lance automates the analysis and creation of alerts in

T+1 by ingest ing standard t rade f i les from a major ity of

OMS/EMS systems, supplemented by Dow Jones

Newswires. The solut ion covers mult ip le venues and

mult ip le asset c lasses, and is integrated with case

management functional it ies.

L iquidMetrix is appreciated for its ease of use and

straightforward implementat ions. It Is part icularly wel l

regarded for its TCA and best execut ion capabi l i t ies. The

Survei l lance solut ion is best posit ioned to serve the needs

of users with lower volumes who are sat isf ied with T+1

rev iew of trade and order data.



L S E G T E C H N O L O G Y – M I L L E N N I U M S U R V E I L L A N C E

LSEG Technology provides capital markets technology

solut ions from pre to post t rade to more than 40

organizat ions global ly through the Mil lennium and GATElab

suite of products . The Mil lennium Survei l lance offer ing is

speci f ical ly targeted to serve the needs of exchanges and

regulators monitor ing exchange -l isted products. The

product covers real -t ime, mult i -market trade and order

survei l lance. The solut ion is currently deployed on premise

and a c loud-based service is being considered. Mil lennium

Survei l lance is deployed global ly , with 14 instal lat ions

spread across Europe, As ia Paci f ic , the Middle East , and

Africa.

Mil lennium Survei l lance identi f ies potential market abuse

through alerts and then presents them to users along with

data v isual izat ions . Within the survei l lance dashboard ,

users can look at mult ip le order books at the same t ime , as

wel l as choose the v isual izat ions best sui ted to their needs

for monitoring both market abuse and trading rules

violat ions alerts. Machine learning techniques have been

implemented to complement the t radit ional alerts and

improve survei l lance outcomes.

Within its alerts management system, Mil lennium

Survei l lance enables c l ients to manage potential cases and

alerts in a sortable , searchable, and t ime organized manner.

The workflow al lows compl iance off icers to m ake notes and

add attachments per alert and categorize sets of alerts.

Market Replay has been recreated from the ground up as a

web appl icat ion al lowing for r icher graphical featur es to a id

visual iz ing the market at a point in t ime and replaying

events.

In an effort to al low cl ients to opt imize the platform to their

own requirements, Mil lennium Survei l lance now

incorporates Scala and Python script ing languages for the

development of alerts , which opens a range of community-

bui lt l ibraries and techniques , including Machine Learning.

Integrat ion with third-party BI tools is also avai lable

through APIs which can add addit ional v isual izat ion

capabi l i t ies to the core funct ions of Mil lenn ium

Survei l lance. LSEG Technology cont inues to explore the

benefi ts of emerging technologies and databases to improve

the eff ic iency and speed of its propr ietary database . LSEG

Technology wil l continue to serve exchanges and regulators ,

with no plans to expand to other types of market

part ic ipants .

LSEG Technology has been successful among smal ler

exchanges in emerging and frontier markets. Breaking into



larger, more establ ished markets and displacing Nasdaq

SMARTS or Sci la wi l l be dif f icul t , not because of any

shortcoming in the Mil lennium system – i t i s readi ly able to

handle the volumes of the London Stock Exchange – but

rather because of s igni f icant inert ia on the part of larger

exchanges.



N A S D A Q S M A R T S S U R V E I L L A N C E

Prior to the acquisit ion by Nasda q in 2010, SMARTS was

founded in Austral ia in 1998. A market leader on the sel l

s ide and amongst regulators and exchanges , Nasdaq

SMARTS survei l lance monitors equit ies , futures & opt ions,

commodit ies, FX, precious metals , f ixed income, dark pools ,

energy, commodit ies, and cryptocurrencies across 165+

global markets , in 35+ countries, with 210+ preconf igured

real-t ime and T+1 alerts. This includes a bundle of alerts

dedicated to monitoring cross-asset manipulat ion.

Through direct feeds, the Nasdaq SMARTS survei l lance

infrastructure sources order and execution data direct ly

from equit ies , der ivat ives and commodit ies exchanges and

MTFs. This setup al lows for a rapid deployment cycle for the

survei l lance of exchange traded instruments as wel l as OTC.

Nasdaq SMARTS is a hosted, turnkey, market leading

solut ion for exchange traded instruments and OTC.

Nasdaq SMARTS has been instal led global ly at marketplaces,

regulators, and market part ic ipants. Via its 2017 acquisit ion

of Sybenetix, a London-based behavioral analyt ics

survei l lance provider, i t is now also making a push into the

buy side. In 2017, SMARTS released the Lens module into

production to complement t radit ional rules -based

discovery. The module provides an enti ty

(t rader/desk/account ) based view of monitoring, integrat ing

signals f rom mult iple compl iance channels and data sources.

The SMARTS platform includes auditable case management.

While Nasdaq SMARTS has an impress ive c l ient base

global ly , uniquely in Asia , this space is f looded by

compet it ion. SMARTS survei l lance has grown at 8% year

over year, but wi l l need to continue moderniz ing to ward off

threats to market share from other top competitors and

newcomers.

F I G U R E 2 1 . N A S D A Q S M A R T S M A R K E T R E P L A Y



N I C E A C T I M I Z E – H O L I S T I C S U R V E I L L A N C E

Founded in 1999, and based in Hoboken, New Jersey, NICE

Act imize has long held a leading pos it ion in t rade and

communications survei l lance market share on the sel l s ide –

without fal l ing into the “ legacy technology” trap where

many of i ts early c lassmates now res ide. Its continued

dominance can be attr ibuted to s ignif icant and ongoing

investments in R&D, as wel l as key acquisit ions by i ts parent

company of Redkite Financial Markets , enabl ing a lower cost

hosted solut ion, and Nexidia, augmenting NICE Actimize’s

text and voice analyt ics. In recent years , NICE Actimize has

s ignif icantly expanded its buy-side cl ient base, and has led

the MiFID II driven charge to provide a hol ist ic service,

combining survei l lance and analys is of both cross -asset

c lass trade data and communication channels. Another key

differentiator of NICE Actimize’s is that its ful l suite of

offerings also addresses sales pract ice and suitabi l i ty

test ing, as wel l as ant i -money launder ing requirements.

NICE Actimize’s c l ie nts (mostly t ier 1 and 2 f inancial

inst itut ions) , are part icularly sat isf ied with the solut ion’s

context-dr iven trade reconstruction capabi l i t ies – with an

upt ick in usage of over 100% over s ince ear ly 2016 . NICE

Act imize had a bi t of a head start on its c ompetitors , as i t

began offering this serv ice for Dodd Frank’s swaps

reconstruct ion requirements. The patented correlat ion

algorithm enables analysts to pul l together al l orders,

quotes , t rades, c lear ing detai ls , t rader informat ion, and

relevant communicat ion data in less than 10 minutes –

enabl ing dai ly use for c l ients ’ internal r isk management .

NICE Act imize’s communications survei l lance capabi l i t ies

leverage natural language processing and behavioral

analyt ics to monitor text and voice communicat ions for

indicators of secrecy, col lusion, bragging, etc. It can survei l

the largest l is t of languages, including: Engl ish , Spanish,

Hindi , Portuguese, Russian, Turkish, Pol ish , French, German,

Japanese, Chinese (Mandarin and Cantonese) , and Korean.

NICE Act imize also aggregates and analyzes a host of

communication channels including: emai l , chat , social , over

600 di fferent types of attachments, f ixed l ine , mobi le ,

turret , and some video. While i ts parent company NICE

Systems is natural partner for voice recordings , NICE

Act imize integrates with many of the other recorders on the

market.

NICE Actimize ’s case management system is al ready widely

considered amongst the best , providing a ful ly auditable

workflow. Its roadmap is also promising, including an

ent ic ing “ent i ty rev iew” to be released in the coming

months, which al lows the compl iance off icer to shi ft f rom

event centr ic invest igat ions , to view alerts in the context of



an indiv idual trader or portfol io manager’s enti re trade and

communications act iv i ty.

F I G U R E 2 2 . N I C E A C T I M I Z E T R A D E


NICE Actimize global c l ients are us ing the Markets

Survei l lance solut ion for al l asset c lasses and across

mult ip le geographies, including advanced capabi l i t ies such

as cross market/cross product manipulat ion and advanced

insider deal ing. Fixed income analy t ics can run with or

without market data. Most of the f irms NICE Actimize

serves al ready have evaluated pr ices in house . However,

there are other benchmarks that the Markets Survei l lance

analyt ics can use, including the f i rm’s own transact ions.

The Actimize Markets Survei l lance Cloud solut ion is a SaaS

solut ion with embedded market data for al l asset c lasses ,

including evaluated pr ic ing data. Monitoring thinly traded

bonds is a chal lenge for al l f i rms, and NICE Act imize is a

leading vendor for OTC survei l lance. Cl ients can augment

their NICE Actimize survei l lance with an addit ional solut ion

by ingest ing alerts to the Enterprise Risk Case Manager to

have s ingle case management and management reports for

al l the survei l lance solut ions.

NICE Act imize’s roadmap looks promising – with its

Autonomous Financial Crime Management platform,

featur ing cont inued investment in hol ist ic survei l lance ,

behavioral analyt ics and anomaly detection, machine

learning, relat ionship mapping, del ivery of f ront off ice

insights, and continued reduct ion of false posi t ives. NICE

Act imize i s wel l posi t ioned in today’s market, and putt ing

this roadmap into act ion should maintain i ts pos it ion of

dominance. Although compet itors are beginning to enter the

r ing as hol ist ic solut ions , NICE Actimize is st i l l the proven

end-to-end solut ion combining both trade and

communications survei l lance in one place.



O N E M A R K E T D A T A – O N E T I C K T R A D E S U R V E I L L A N C E

Created in 2015 by OneMarketData to perform intraday

trade survei l lance for the buy and se l l s ide, OneTick Trade

Survei l lance serves c l ients in Europe, the United States , and

Austral ia. Running on OneMarketData ’s OneTick data

management platform, OneTick Trade Survei l lance’s n iche is

providing survei l lance capabi l i t ies to market part ic ipants

trading high volumes, with several c l ients requir ing the

processing of hundreds of mil l ions of orders per day. Most

users of OneTick Trade Survei l lance also employ th eir

survei l lance provider to meet best execution report ing

requirements.

Based in Hoboken, New Jersey, OneTick Trade Survei l lance

can be deployed both on si te and hosted, with about 70% of

c l ients choosing the latter. Cl ients log -in to the system via

a password protected URL only accessible from their off ice.

The cross asset c lass alerts are typical ly produced for

c l ients in T+1 t imeframe, after process ing t rade and order

data overnight. For c l ients unable to del iver trade and order

data in an easi ly ingested format , OneMarketData also

offers data normal izat ion.

While the system comes preconfigured with 20 di fferent

alerts types , users are able to adjust parameters in real -t ime

to ensure al l desi red scenarios are monitored. Back test ing

al lows users of the system to veri fy that alert ing is

appropriately targeted for their needs. Back test ing can also

be used to aid in trade reconstruct ion requirements.

OneTick Trade Survei l lance also includes a sanity checker

for the t rade and order data.

F I G U R E 2 3 . O N E T I C K S U R V E I L L A N C E

The solut ion comes preloaded with market news feeds

provided by OneMarketData’s exist ing partnerships,

considered alongs ide posi t ion accumulat ion over general ly

a 30 day t ime period in order to create insider trading alerts.

This approach to detecting potential ins ider t rading is

part icularly wel l rece ived by its users. While OneTick does



not provide its c l ients with evaluated pric ing to help with

the survei l lance of f ixe d income, for example, i ts hosted

solut ion can ingest a c l ient ’s dist inct data sources to be

used for analysis .

OneTick Trade Survei l lance comes with case management

functional it ies that al low for the t racking of false posi t ives.

In a future iterat ion of the solut ion, machine learning wil l

be deployed to score a lerts based on how close the alert i s

to a typical alert of a given type. Invest igat ion workflow is

auditable , al lows for escalat ions and role assignment, and

enables the grouping of alerts for eff i c ient handl ing.

Interact ive visual izat ions can be customized based on the

users’ needs and permissions. Al l alerts are described in

written language. Order/trade l i fecycle graphics help to

present a bi rds eye view of events tr iggering the alert .

Future plans for OneTick Trade Survei l lance include

employing machine learning to help make sense of alerts

l ikely worthy or unworthy of further attention. MiFID I I has

been a big dr iver for bus iness towards OneTick Trade

Survei l lance solut ion in the last few years , and with its

current roadmap put into real ity should cont inue to make its

c l ients happy.



R I M E S T E C H N O L O G I E S – R E G F O C U S M A R K E T S U R V E I L L A N C E A N D M A R

RIMES Technologies , the managed data service provider,

expanded into RegTech in 2016 with new solut ions

addressing market survei l lance requirements for the sel l -

s ide, the buy-side, hedge funds and algorithm traders.

RegFocus Market Survei l lance and MAR is a p latform geared

towards equipping f inancial inst itut ions with market

survei l lance capabi l i t ies, including MAR and MiFID I I

requirements, to ensure their trade and order monitoring

are up to par. Although the f i rst c l ients for RIMES’ hosted,

cross-asset , and cross-market survei l lance solut ion came

from the buy-s ide, they now also include sel l -s ide c l ients.

The platform excels at f ixed income – a stumbl ing block for

many establ ished players – as i t comes preloaded with data

( f rom RIMES’ managed data s ide o f the bus iness) . RIMES has

already won s ignif icant c l ients away from incumbents with

its f ixed income and OTC capabi l i t ies. Data coverage is

another strength of the platform, together with a unique

abi l i ty to adjust parameters and thresholds to asset c lass es

and type of transact ion (order, t raded, f i l ls , etc ) . This

represents the latest trend in monitoring, cal led “dynamic

threshold”. Flexible architecture al lows cl ients to integrate

RIMES solut ions with other instal led technologies.

F I G U R E 2 4 . R E G F O C U S M A R K E T S U R V E I L L A N C E

With RegFocus MS & MAR, c l ients also have their MiFID II

requirements addressed. The tools can be used to generate

best execution analyses and reports as wel l as run

transaction reports for T+1 submiss ion to an Approved

Report ing Mechanism (ARM).

Although RIMES’ surve i l lance solut ions are relat ively new to

the market, they are able to handle the very t r icky

survei l lance requirements of algor ithm trading f i rms

including helping with the obl igat ion of test ing an aglorithm

before going into production. The platform includ es an

extremely comprehensive coverage of asset c lasses. I t i s a

known fact that a front running market event for equity wi l l

not work for f ixed income, hence al l detect ion models have

been developed by asset c lass.



RIMES’ solut ions are typical ly priced b y user numbers,

models and asset c lasses covered, making them part icularly

appeal ing for inst i tut ions just beginning to shoulder

responsibi l i ty for survei l lance themselves , rather than

rely ing on their brokers. In addit ion to survei l lance for the

prevention and detection of market abuse and insider

trading, RIMES also offers a separate compl iance platform

which takes care of al l EU Benchmark Regulat ion

requirements.



S C I L A – S C I L A S U R V E I L L A N C E

Founded in Stockholm in 2008, Sc i la Survei l lance has over

35 instal lat ions global ly , winning 12 new deals in 2017. It

has the second largest market share global ly for t rading

venue survei l lance (after Nasdaq SMARTS), and serves

trading f i rms and regulators . Sci la has been notably

successful winning deals with large a nd mid-large

power/commodit ies f i rms and regulators. Interest ingly , a

few buy-side f irms use the solut ion primar i ly to monitor

the ir competitor’s behavior to better respond to other f i rms’

trading strategies. Cinnober is 27% shareholder, but Sci la

operates independently.

Sci la covers al l asset c lasses ( including cryptocurrencies) ,

e ither on premise or hosted with pos it ion t racking for t rue

performance management. Alerts are created to consider

historical data benchmarking trader behavior, market

anomal ies , pr ice alerts , and instrument volat i l i ty . Cl ients are

able to ref ine alert parameters and reports with the

assistance of back test ing capabi l i t ies. The Sci la system is

database agnostic and makes use of standards API protocols

for further integrat ions. Pri or it iz ing scalabi l i ty , Sci la

processes over 50 bi l l ion messages dai ly at i ts largest

instal lat ion at the NYSE.

Machine learning is currently deployed by Sci la at large

exchanges and other c l ients to t rain the classi f icat ion of

alerts – with the goal of minimiz ing false pos it ives . The next

step wil l be to apply machine learning on top of the

stat ist ics currently used.

Case management has been bui l t out. Users seem

part icularly pleased with the market replay and ini t ial t rade

reconstruct ion support provided, but integrat ions with

outside case management systems are also supported at the

cl ient ’s request.

One large bank has already asked for voice t ranscript ions to

be included in Sc i la ’s case management system, correlated

to t rade data. Sc i la also has the capabi l i ty to ingest broader

e-comms, news, and events feeds and to correlate these

with t rading data , as wel l as provide MiFID I I compl iant

archiving. A few cl ients now leverage Sci la in this way.

Sci la has strategical ly p osi t ioned itsel f to win deals based

on their technical f lexibi l i ty – versus other more

standardized incumbents. Already , they del iver c l ient

requests that go beyond market abuse survei l lance

requirements by bui ld ing custom reports for c l ients ’ needs,

including best execution RTS 27 & 28. Th rough a mix of

replacing internal systems as wel l as incumbent survei l lance

solut ions , Sci la should continue to expand its footpr int .



S I A - S I A E A G L E S U R V E I L L A N C E

Headquartered in Milan, S IA offers trade survei l lance to

exchanges, regulators, and sel l -s ide f i rms. The company is

start ing to see buy -side interest for the EAGLE Survei l lance

solut ion as wel l . Most of SIA EAGLE’s c l ients are located in

Italy , Hungary, and Germany, though it has addit ional

implementations scattered throughout Europe. Alongside

survei l lance for market abuse scenarios , the solut ion

monitors for confl ict s of interest , ins ider deal ing, and best

execution. Currently , about 20 cl ients are using the system,

either on premise (80%), or as a hosted service (20%) v ia

one of SIA’s two data centers in Italy.

SIA EAGLE offers both real - t ime and post-trade

survei l lance, depending on the market part ic ipant ’s needs ,

across al l asset c lasses and markets. Considerat ions for

threshold sett ing include: the type of f inanc ial instrument

analysed, l iquidity, algori thms used, volumes, and even

source IP address. The solut ion integrates market news and

corporate act ions, and comes with pric ing feeds del ivered

through SIA’s partnership with SIX Financial Informat ion.

In a standard deployment , S IA EAGLE loads a c l ient ’s

historical data to train the alert ing algor ithms, and engages

the annual ly rev iewed thresholds. Cl ients are a lso set up

with a case management system that al lows alerts to be

f i l tered by date , algor ithm, involved trader, etc. The

recently renovated dashboards provide t rading act ivi ty

visual izat ions for the cl ient ’s ful l book of instruments,

including t ime per iod, pr ic ing, and volume information.

Users can then dri l l down into the data to better understand

usual and unusual behaviour and the networks of traders

be ing monitored.

While the company is considering integrat ing

communications data into the survei l lance platform, there is

not currently a plan in motion. SIA EAGLE Survei l lance has

a long track record of serv ing a variety of c l ient types across

Europe. With broad asset c lass coverage, the stat ic rules -

based system provides bas ic alert ing required for regula tory

compl iance.

F I G U R E 2 5 . S I A E A G L E T R A D E S U R V E I L L A N C E



S O F T W A R E A G – A P A M A E A G L E E Y E

Germany based Software AG brought i ts Apama EagleEye

survei l lance offering to market early in 2018, though i t has

offered trade survei l lance to c l ients via Market Survei l lance

and Monitoring for several years. With Apama EagleEye,

Software AG offers i ts c l ients a s ingle pane of glass view of

alerts created for t rade, order, and behavioural data,

alongs ide communications information ingested from third

party channels.

The solut ion del ivers a customizable catalogue of alerts to

its c l ients, and Software AG works with c l ients to create

addit ional scenarios where the need arises. The solut ion has

prior it ized conf igurabi l i ty – ta i lorable by asset c lass ,

geography, or organizat ional unit . Alerts can be run on real -

t ime or historic data depending on the users’ needs,

consider ing t rade, order, news, and market da ta.

The Apama EagleEye case management is ent irely new

technology, bui l t to pr iorit ize workflow and conf igurabi l i ty.

Dur ing the course of an invest igat ion users can attach

evidence in an auditable and unchangeable manner, with

every act ion t imestamped. The system al lows the

assignment of roles and permiss ions and enables data replay

for invest igat ive purposes. Interact ive v isual izat ions help

the compl iance off icer further understand the context of an

alert . Users can group alerts to invest igate or resolve i tems

more eff ic iently.

F I G U R E 2 6 . S O F T W A R E A G A P A M A E A G L E E Y E

Apama EagleEye also is able to ingest thi rd party

communications and map this to t rade and order

survei l lance alerts surfaced. While alerts are not currently

produced from communicat ions data, the offering does

provide v isual izat ions l ike relat ionship maps. Users are ab le

to group people by their organizat ional unit in these

visual izat ions in order to get a better sense of

communication f lows.

The Apama EagleEye roadmap includes enhancing report ing

capabi l i t ies – a l lowing users to conducts further analyses of



invest igat ive efforts , including s l ic ing monitored data by

geography or type of alert . Planning is also underway to

produce more di rect communications analyses to better

identi fy outl ier act iv i ty. In future i terat ions the solut ion

aims to also improve the detection of rogue trading by

including detai ls about expense reports and the t ime of day

at which a t rader or portfol io manager is act ive.



T H E T E C H N A N C I A L C O M P A N Y - J A N U S S U I T E

The Technancial Company, a subsidiary of IT SOFTWARE,

offers the JANUS Suite which i ncludes JANUS Risk Manager

for real -t ime transact ion monitor ing, JANUS Trade

Survei l lance for market abuse monitoring. The solut ions

or ig inated after the market chaos of 9/11 in 2001, in it ial ly

to monitor equit ies, then f ixed income ( responding to

demand in Italy ) , and then futures & options. Headquartered

in London, Technancial has continued to update i ts solut ions

to address the European Market Abuse Regulat ion and then

extended to other geographies and regulat ions , including

MiFID II and Dodd Frank. Whil e many of the JANUS cl ients

are in Europe , Technancial has extended sel l -s ide customer

deals in Asia Pac if ic and more recently global ly . These

cl ients include two global US, one UK and a French sel l -s ide

bank. Other c l ients are t ier 2 and 3, global ly distr ibuted –

with 30 in total in 11 countr ies. While init ial instal lat ions

were for the sel l s ide , Technancial has also started signing

on the buy side. Inst i tut ions selected JANUS for the real -

t ime as wel l as ‘ look back’ monitor ing capabi l i t ies, as up to

date alert ing has become more essential with t rading

automat ion.

The JANUS Suite of monitor ing products includes JANUS

Trade Survei l lance, a cross -market, mult i -asset market

abuse monitor ing solut ion. Users benef it f rom the f lexibi l i ty

to edit alert rules and controls for di fferent order f lows. The

80 plus rules in JANUS Risk Manager represent

comprehensive controls and immediate act ion in the event

of a cri t ical breach occurring. Technancial has pr iori t ized

developing smart alerts and reducing the t imewasting false

posi t ives. Recently adding FX, Technancial i s invest ing in

improving survei l lance qual ity for th is asset c lass.

F I G U R E 2 7 . T H E T E C H N A N C I A L C O M P A N Y -

J A N U S S U I T E



The solut ion now includes JANUS Behavioral Analyt ics , with

capabi l i t ies that retain the historical data of c l ients and

traders to identi fy bus iness insights , l ike the account

performance, portfol io r isk s ize relat ive to act ivi ty, use of

avai lable l imits , and trader performance. Technancial also

offers both T+1 and real -t ime monitor ing – including

electronic t rading for MiFID II RTS 6 compl iance. Real -t ime

is especial ly important for HFTs and propr ietary t rading

desks, where a misprogrammed algor ithm can spel l d isaster.

The case management functional ity in JANUS is intuit ive

with a c lean workflow. Ful ly auditable and customizable per

cl ient ’s des ired role assignments, the system al lows

database searches, compl iant storage, and the inclusion of

attachments in alert invest igat ions. The Technancial

Company does not yet offer MiFID I I compl iant t rade

reconstruct ion report ing as a service and does not have

plans to get itself into the communicat ions monitoring

space. With the plan in motion to deepen alert qual ity per

asset c lass, Technancial i s wel l posi t ioned to continu e

winning deals in its sweet spot : Medium -sized banks and

global brokers.



T R A D I N G H U B - M A R K E T A B U S E S U R V E I L L A N C E T O O L ( M A S T )

TradingHub successful ly pos it ioned its Market Abuse

Survei l lance Tool (MAST) to large European buy -side f i rms

($2B and over) when i t hit the market a few years ago. Its

momentum has not subs ided and TradingHub continues to

grow, expanding both geographical ly to North America, and

by serving new types of c l ients including the sel l s ide and

regulators l ike FINRA. Greenhoused by 20% shareholder IHS

Markit start ing in 2010, the independently run TradingHub

also provides rogue trader detection and trader

performance assessment services alongside MAST.

This cross-asset c lass solut ion is often referred to, eve n by

compet itors, as a promising example of advanced

approaches being used to reduce false pos it ives.

TradingHub claims to remove about 95% of the false market

abuse alerts incumbent solut ions produce during a shock to

the market – Brexit , for example. Qua ntitat ive threshold

sett ing, tracking of standard deviat ion of pr ice movement to

assess instrument volat i l i ty by type, consider ing a 12-month

rol l ing window of market data, and the appl icat ion of

techniques l ike the Monte Carlo method ( repeated random

sampl ing to obtain results ) , are al l e lements that comprise

TradingHub ’ s alert ing methodology.

MAST also identi f ies market abuse using trader metrics

which highl ight and invest igate t rader outperformance .

Where, for example a t rader demonstrates an abi l i ty to

capture mult ip le market shocks , a propensity to avoid

losses, or a tendency to gain outsized prof its whi le taking

relat ively smal l r isks. While such performance metrics,

perhaps cal led behavioral analyt ics by some, can obviously

be fed back to the Head of Trading who can try to optimize

their team – this information is also fed into the alert ing

algorithms for the detection of market abuse.

F I G U R E 2 8 . T R A D I N G H U B S U R V E I L L A N C E

D A S H B O A R D



Some t ier 1 sel l s ide c l ients keep MAST on premise, but al l

remaining t ier 2 and buy side TradingHub users run a hosted

solut ion. Preconfigured with market news feeds, MAST is

l ive at about 30 cl ient s i tes , with several addit ional p i lot

programs al ready of f the ground. The platform is integrated

with immutable and auditable case management capabi l i t ies.

TradingHub has developed a pos it ive reputation, even

amongst i ts peers. Rumor is that it has served as inspirat ion

for even never entrants to the survei l la nce space focusing

on serving f inancial inst itut ions. Some prospects may be put

off by the fear of alert ing methodology not yet being tested

by regulators threatening f ines, but TradingHub is a solut ion

incumbents should keep on their radar. While not the most

inexpensive tool , i ts future looks bright i f i t is able to

continue pleasing its customers and bui ld a tested resume

of keeping regulatory f ines at bay.



T R A P E T S – I N S T A N T W A T C H M A R K E T & O U T S O U R C E D T R A D I N G S U R V E I L L A N C E

Stockholm-based Trapets began offer ing the InstantWatch

Market survei l lance solut ion in 2005, and has become a

dominant player in northern Europe serving regulators ,

exchanges, MTFs, the sel l s ide, and the buy side. Trapets’

platform for automatic survei l lance analyses trade, order,

and news f lows from exchanges and MTFs in real t ime or in

batch. Either on si te or hosted, InstantWatch Market

posi t ions i tsel f to help c l ients comply with MiFID II , MAR

and ESMA guidel ines on market abuse and insider t rading

survei l lance .

The InstantWatch Market platform produce s cross-market

and cross-asset c lass alerts according to a rule-based

system, preloaded with 50-60 configurable alerts. The

alert ing thresholds , based on volat i l i ty and standard

deviat ion calculat ions , d if fer per asset c lass and are

reworked each night . The system is bui l t to provide more

than 2 mil l ion alert tr igger checks per second – making i t

scalable enough to support the needs of an HFT. Trapets ’

conf igurable c l ient dashboard includes auditable case

management capabi l i t ies , data visual izat ion options ,

orderbook replay, and best execut ion analysis .

F I G U R E 2 9 . T R A P E T S I N S T A N T W A T C H M A R K E T

D A S H B O A R D

A unique dif ferent iator of Trapets, i s i ts Outsourced Trading

Survei l lance (OTS) offer ing. ESMA technical standards

al lows for outsourcing in survei l lance , so Trapets offers to

perform the day-to-day survei l lance work on behal f of c l ient

us ing InstantWatch Market. This outsourced real-t ime or

batch (for buy s ide) alert management service especial ly

appeals to market part ic ipants w ho are too smal l to hi re a

ful l -t ime compl iance off icer, need to augment their exist ing

team, or would l ike back-up avai lable for their compl iance



teams. Al l communication between Trapets and cl ient s i s

documented within the platform, including dec is ions on

whether or not to submit a STOR report fol lowing an alert .

With the broad range of instruments covered , famil iar ity

serving many types of c l ients , several options for

deployment, and compl imentary KYC and AML offer ings,

Trapets should wel l be able to further expand outside of

northern Europe. Lately , Trapets has expanded their

offering with MiFID I I services, including a id ing in trade

reconstruct ion. With i ts f i rst InstantWatch Market c l ients

already on board in Bangladesh and Argentina, we expect to

hear more from Trapets outs ide of Europe.



T R I L L I U M S U R V E Y O R

The 2014 technological offspring of proprietary t rading f i rm

Tr i l l ium, Tri l l ium Surveyor is focused speci f ical ly on North

American cl ients trading equit ies, options, and futures. This

solut ion was created to address an internal need fol lowing

a FINRA investigat ion at Tri l l ium for layer ing and spoofing.

Surveyor is des igned to preempt such a regulatory inquiry,

avoid f ines, and mit igate potential reputational damage.

This trade and order survei l lance offer ing is targeted at sel l

s ide f irms, prop shops, and quant funds who do signif icant

volume.

Within equit ies , futures, and opt ions , Surveyor offers T+1

cross product survei l lance as wel l as monitor ing for cross

market and cross product v iolat ions. The depth of order

book analysis i s part icularly wel l suited for the reduction of

false pos it ives for spoofing and layering. The so lut ion

al lows users to automate the classif icat ion of alerts before

they are escalated, and the windows based front end is

intuit ive to navigate and populated with visual izat ions that

aid in alert invest igat ions, including orderbook replay. The

solut ion is currently hosted in Tri l l ium ’ s private c loud, but

a migrat ion to Amazon Web Services is underway, expected

to be completed by year end 2018. Tri l l ium provides the

market data used for alert creat ion . The platform is

conf igurable by Tri l l ium’s engineering staff only , but

parameter changes can be made overnight and new features

are added monthly.

F I G U R E 3 0 . T R I L L I U M M A R K E T V I E W E R

S H O W I N G C R O S S - P R O D U C T A L E R T

Special attention has been paid to develop v isual izat ion

within the platform, and Surveyor also includes natural

language storyboards that produce alert explanations in

plain Engl ish. Most Tri l l ium cl ients use the case management

functional it ies within Surveyor , though some use their own

separate systems. In these situat ions , case management

workflow notes , together with relevant support ing

posi t ions, news, and market data needed for analysis , are

sent via pdf with charts di rect ly to the reviewers.



Tri l l ium has thus far focused on the United States and

Canada, with l imited coverage of European futures markets

only. Future plans inc lude expanding asset c lass coverage

and making alerts avai lable in near real t ime (currently alerts

are generated T+1 only) .



L O O K I N G F O R W A R D

Even with Nasdaq SMARTS and NICE Act imize owning over

half of the US$284mn spend on trade survei l lance software,

new entrants are aggress ively entering the r ing . Recently

there has been a t rend for regulatory report ing hubs to get

in on the game. UnaVista plans to rol l out market abuse

alert ing and report ing this year v ia its UnaVista Transact ion

Intel l igence offering. Sapient is cons idering creating a

formal offer ing off of the back of an engagement for a

part icular c l ient. Analyt ics providers are also employed from

t ime to t ime to help c l ients meet survei l lance requirements

– SAS and London-based start-up SteelEye, have both been

assigned such tasks. Euronext Technology Solut ions is al so

throwing its hat in the r ing , p lanning to offer market abuse

report ing powered by Kx leveraging kdb+ Big Data

capabi l i t ies.

Some of the newcomers wil l l ikely struggle to get a

sustainable foothold in this very competi t ive space. A

consol idated cl ient base is an essent ial advantage that more

establ ished solut ions have , al lowing them to f inance efforts

required to keep their systems up to date . Upgrades require

funding, and external investment can only carry a f i rm so

far.

We expect to see some of the leading providers acquire or

partner with complementary smal ler solut ions , and that the

f ie ld of t rade survei l lance vendors wil l shr ink over the next

12-18 months.



About the Report 's Author

Anna Griem is a senior analyst in Opimas’ equit ies t rading pract ice and has publ ished reports on a

variety of top ics , including MiFID I I and RegTech.

About Opimas

Opimas is a management consultancy focused on capital markets, serv ing leading f inanci al

inst itut ions around the world. Our special i sat ion al lows us to bring our expert ise to bear from the

very beginning of projects, to provide insight and craft st rategies for our c l ients more quickly ,

without sacr if ic ing qual ity. Opimas continuously invest s considerable resources, representing

about one thi rd of our revenues , in market research. This investment al lows us to create a pool of

intel lectual capital on issues of strategic importance to our c l ients.

Uniquely in the consult ing industry, Opimas pur sues an ent irely open approach to knowledge

sharing, providing our c l ients direct access to our enti re pool of inte l lectual cap ital . This gives our

c l ients the lat itude either to support their st rategic decis ions independently, whi le relying on our

knowledge base , or to engage direct ly with our consultants on a project basis .

http://www.opimas.com

mailto:[email protected]

https://www.linkedin.com/company/opimas-llc

callto:+13124048195

https://www.youtube.com/channel/UCvot3e87YA667e2f-roE0qA

Shortlisting Trade Surveillance Solutions - info.nice.com · While visualization and a...

Documents

Transcript of Shortlisting Trade Surveillance Solutions - info.nice.com · While visualization and a...