Market Conduct of Business

Regulators expect firms to operate adequate, effective and sustainable controls that prevent financial crime occurring in investment markets. 

There’s a considerable amount of focus on market conduct; assessing and managing the behaviours of brokers as well as ensuring that customers are aware of the risks associated with making investments. Regulators expect firm’s financial crime controls to be aligned, driving  AML teams and those teams surveilling market activities closer together.

We’re seeing a lot of challenges to firms’ surveillance arrangements on the coverage and depth of review and analysis. This will continue to be important to regulators and firms as will the continued focus on benchmarks, barriers and the management of conflicts.

As the new Consumer Duty is implemented, there will be increased focus on manufacturers of investment products that are tailored for the retail market.

Our Approach

We work with all firms operating in the investment market, including banks, wholesale and retail asset managers, hedge funds and venture capitalists, private banks and wholesale and retail brokers. We tailor our approach to the firm, its customers and services.  Our solutions reflect the scale of the business, the regulatory, operational and reputational risks it faces, the risk of potential harm to its customers and the risk of financial crime. Our team has worked in markets businesses on trading floors, in control rooms and  in compliance and risk leadership roles. We combine this practical experience with our consulting expertise to deliver sustainable solutions.

Our Services

We offer a range of services including skilled person reports, independent assurance, past business reviews, advisory mandates and project delivery support. We also provide training and resources to businesses to ensure that their business models align with regulator expectations.

We typically work with firms on their arrangements for:

Trade execution

Best execution, arrangements in multilateral and organised trading facilities and how firms act with their customers in a trading capacity.

Trade surveillance

The adequacy, effectiveness and sustainability of platforms, the consideration of alerts, the treatment of suspicions and the roles and responsibilities for acting upon the outputs of surveillance, whether in relation to trade or voice arrangements.

Conflicts of interest

How conflicts are managed, cleared, reviewed and escalated.


The remuneration for staff in trading roles and how this incentivises appropriate behaviours. We help firms to:

  • Design of front and back offices
  • Implement, review and improve control environments and compliance and risk functions
  • Ensure their frameworks have full coverage and are operating effectively