Trade Surveillance & Market Abuse Monitor

The Trade Surveillance & Market Abuse Monitor collects employees' personal trading from their brokers, checks it against your restricted and watch lists, pre-clearance approvals and the firm's own trading, and flags patterns that look like front-running or trading on inside information. Compliance reviews each exception, records the outcome and follows up with the employee. Holdings reports, quarterly transaction reports and annual certifications are collected and tracked in the same place, ready for examiners.

The problem it solves

Code of Ethics programs are often run from broker statements arriving by mail or email, a pre-clearance inbox, a restricted list kept in a spreadsheet and reminders sent by hand. Matching an employee's trade to the firm's own orders or to a name on the watch list is slow, so reviews are sampled or late. When an examiner asks how a suspicious personal trade was found and what was done about it, the evidence is in several places.

Who it’s for

• Chief compliance officers at investment advisers, broker-dealers and fund complexes
• Compliance analysts who review personal trading day to day
• Control room and research staff who maintain restricted and watch lists
• Employees designated as access persons who must pre-clear and report their trades
• Internal audit and examiners, who need evidence of every review

1. Pre-clearEmployees request approval before they trade. The request is checked automatically against the restricted list, blackout periods, holding-period rules and open firm orders, and compliance decides on anything that is not clear-cut.
2. CollectPersonal trades and holdings arrive from brokers by electronic feed or uploaded statement, and are matched to the employee and the account they declared.
3. MonitorEach personal trade is compared with pre-clearance approvals, the restricted and watch lists, and the firm's and its clients' trading in the same security, to find unapproved trades and patterns such as trading ahead of client orders.
4. ReviewCompliance works each exception, contacts the employee where needed, and records the outcome, from no action to escalation. The chief compliance officer approves sanctions and escalations.

Pre-clearance

Employees request approval in a form or by email reply, with automatic checks against lists, blackouts, holding periods and open orders before compliance decides.

Broker feeds and statements

Trades and holdings loaded from brokers' electronic feeds where they exist, and from uploaded statements where they do not.

Restricted and watch lists

Lists maintained by the control room with effective dates, reasons and history, so every check uses the list as it stood on the trade date.

Front-running detection

Personal trades compared with client and firm orders in the same security, with the time between them shown so a reviewer can judge the pattern.

Explainable exceptions

Every exception states the rule, the trade, the related order or list entry and the timing, in words an examiner can follow.

Holdings and transaction reports

Initial and annual holdings reports and quarterly transaction reports collected from access persons, with due dates and reminders.

Annual certifications

Employees acknowledge the Code of Ethics and its amendments, and the acknowledgment is kept with the date and version.

Holding-period and blackout rules

Minimum holding periods and blackout windows around fund trades, research or deals, configured to your Code of Ethics.

Account declarations

Employees declare their own and household accounts, and new or closed accounts are tracked with the broker information needed for duplicate statements.

Exception case management

Assignment, employee contact, notes, attachments and an approval step before any escalation or sanction.

Exam-ready audit trail

Who requested, approved, reviewed or changed what, and when, for every request, trade, exception and list entry.

Employee self-service

Employees see their own requests, approvals, reporting obligations and outstanding items, and nothing about colleagues.

Employee (access person)

Requests pre-clearance, declares accounts, and submits reports and certifications

Compliance analyst

Decides pre-clearance requests that need judgment and reviews exceptions

Chief compliance officer

Owns the Code of Ethics program, approves escalations and sanctions, and sees everything

Control room

Maintains the restricted and watch lists and blackout periods

Auditor or examiner (read-only)

Views requests, exceptions, reports and the audit trail, with no ability to change them

Administrator

Manages users, roles, brokers and configuration without access to investigations

Broker trade and holdings feeds

Electronic feeds of employee trades and holdings from brokers that provide them, and uploaded statements from those that do not.

Order management system

Client and firm orders and executions, so personal trades can be compared with the firm's own activity.

HR system

Employee starts, leavers, departments and role changes, so access-person status and reporting obligations stay current.

Security master

Identifiers, issuers and related instruments, so a restriction on an issuer catches its options and other related securities.

Research and deal systems

Events that should place a security on the watch or restricted list, sent to the control room for decision.

Single sign-on

Employees and compliance staff sign in through your identity provider (SAML or OpenID Connect).

Work API

Requests, exceptions and outcomes available to your data warehouse and reporting tools through the Moraph Work API.

Single sign-on

Employees and compliance staff sign in through your identity provider, so your password and multi-factor policies apply.

Role-based access

Employees see only their own records; reviewing an exception is separate from approving a sanction.

Confidential lists

The watch list is visible only to the roles you choose. Employees see whether a request is approved, not why a security is on a list.

Encryption and keys

Client data is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.

Complete audit trail

Every view, change, decision and export is logged with the person and time, and cannot be edited.

Data residency

Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Moraph cloud

Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for firms outside the US.

Dedicated environment

A single-tenant environment for firms whose policies require isolation, scoped in the proposal.

With a managed service

Optionally run alongside a Moraph managed service for broker feed management and platform administration.

Code of Ethics mapping

We translate your Code of Ethics into rules: who is an access person, which securities are covered, holding periods, blackouts and pre-clearance requirements. We need your current Code and a contact in compliance.

Broker connections

We set up electronic feeds with the brokers your employees use where feeds are available, and a statement upload process for the rest.

Firm trading data

Order and execution data from your order management system is mapped so personal trades can be compared with client and firm activity.

Lists and rules testing

Restricted and watch lists are loaded with their history, and rules are run against a recent period of trading and reviewed with your chief compliance officer before go-live.

Employee onboarding

Employees are invited to declare accounts, submit initial holdings and acknowledge the Code, with reminders managed by the product.

Training and go-live

Compliance staff are trained on review and approval, employees receive short guidance on requests and reporting, and open items are migrated by agreement.

• The Monitor flags patterns for review; it does not decide that insider trading or front-running took place. Your compliance staff make that judgment and record it.
• Monitoring covers employee personal trading under a Code of Ethics. It is not a market-wide surveillance system for client or proprietary trading on exchanges.
• Results depend on brokers providing complete and timely feeds or statements, and on employees declaring their accounts.
• Comparison with firm and client trading requires order and execution data from your order management system.
• It does not review employee communications. Email and chat surveillance needs a separate archiving and review tool.
• Gifts, entertainment, political contributions and outside business activities are not included.
• It does not file regulatory reports or make referrals to regulators; those decisions and filings are made by your firm.
• Rules are configured from your Code of Ethics; changing the Code and its rules is your firm's decision.

• Load a recent period of anonymized personal trades and firm orders and compare the exceptions with those your current process found
• Ask an employee to submit a pre-clearance request and see which checks run before compliance is involved
• Check that each exception's explanation would satisfy your examiners
• Review how restricted and watch list history is kept and applied to past trade dates
• Walk through an escalation from exception to chief compliance officer approval
• Confirm what employees can and cannot see, including the watch list