From Policy to Practice: Building an Effective Firm-Wide Surveillance Program

Moving from surveillance policy to practice requires focus, the right tools, and a clear understanding of your firm’s unique risks. It’s about turning high-level principles into actionable processes that can adapt to real-world complexities.

Whether your firm is regulated by the UK FCA, U.S. SEC, FINRA, CFTC, FinCEN, or authorities like the DFSA in the Dubai International Financial Centre or FSRA in the Abu Dhabi Global Market, adopting a proactive, risk-based approach to oversight is essential to identifying and addressing compliance gaps. To assist, we’ve developed a comprehensive checklist to help you assess the effectiveness of your compliance oversight, monitoring, and surveillance programs.

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Why build a robust surveillance program?

Surveillance is more than a regulatory checkbox; it’s an essential strategy for navigating today’s compliance challenges. A strong program can help you:

• Proactively manage risk: Early identification of vulnerabilities enables firms to address issues before they escalate into regulatory scrutiny.
• Enhance regulatory resilience: An adaptable surveillance strategy helps firms keep pace with evolving rules.
• Boost operational efficiency: Leveraging advisory services, outsourcing, and regulatory technology solutions can streamline processes and free up resources for strategic priorities.

Putting compliance into action

Turning policies into practice embeds compliance into the fabric of your firm’s operations.

Here’s how to get started:

1. Build awareness

Employees are the first line of defense in any compliance program. They must understand the “why” behind policies and how they safeguard the firm.

• Provide continuous training: Scenario-based training is particularly effective, providing employees with real-world examples like insider trading or conflicts of interest can increase engagement.
• Encourage communication: Clear and consistent messaging reinforces expectations, especially in remote or hybrid work environments where oversight may be limited.

2. Leverage technology

Modern compliance demands modern solutions. Manual oversight is resource-intensive and prone to human errors; technology can operationalize surveillance more effectively.

• Integrate tools: Ensure surveillance systems integrate seamlessly with existing systems, like trade reporting platforms and communication monitoring solutions.
• Develop agile systems: Use tools like AI-powered alerts that evolve with your firm’s changing risk profile.

3. Establish accountability

Policies without accountability are ineffective. Assigning clear roles can help ensure all tasks are completed.

• Designate ownership: Assign individuals or teams to oversee specific compliance areas, such as trade surveillance or sanctions checks.
• Conduct audits: Regular audits confirm adherence to compliance practices and uncover areas for improvement.

4. Test and refine your program

Continuous testing can help your compliance program remain effective and ready to withstand regulatory scrutiny.

• Simulate scenarios: Conduct mock exams or simulate breaches to test readiness.
• Address gaps: Use findings to refine policies and strengthen vulnerabilities.

Strengthen your organization

A well-executed surveillance program that successfully bridges the gap from policy to practice does more than mitigate regulatory risks. It reinforces your organization’s integrity. With the right mix of awareness, technology, accountability, and testing, your firm can confidently navigate today’s regulatory complexities.

How we help

At ACA, we empower firms to bridge the gap from policy to practice. Our GRC solutions integrate advisory expertise, managed services, and innovative technology to help firms operationalize compliance, streamline workflows, and stay ahead of regulatory demands.

Here’s how we can support your surveillance program:

• Strengthen compliance, surveillance, and cybersecurity: Address key areas such as market abuse, AML, eComms monitoring, and data protection to mitigate risks.
• Achieve audit-readiness: Prepare for regulatory scrutiny through mock exams and alignment with industry standards in ESG and performance practices.
• Optimize compliance workflows: Streamline operations with advanced technology solutions that enhance operational efficiency and re-secure business practices.

From mock exams to AI-powered surveillance, ACA provides tailored support to meet your firm’s unique needs. Contact us today to learn more.