The pandemic has disrupted the trading model, compounding the complexity of pre-existing macroeconomic and client drivers and leading to greater ecosystem risks in areas such as conduct and cyber security. Accenture is positioned to provide immediate support to help organizations respond to the virtual trading floor implications from the pandemic crisis. Review our presentation to learn more about surveillance transformation approaches. 

1. July 2020
Transforming
Surveillanceinan
UncertainWorld

2. Industry
Backdrop

3. MACROECONOMIC TRENDS CLIENT DRIVERSECOSYSTEM
Industry Context and New Market Trends
The pandemic has disrupted the trading model, compounding the complexity of pre-existing macroeconomic and
client drivers and leading to greater ecosystem risks in areas such as conduct and cyber security
“Will the Virtual Trading
Floor become the New
Reality?”2
“Surveillance of Homebound
Wall Street Traders Relies on
Pen and Paper”1
“Managers turn to surveillance
software, always-on webcams
to ensure employees are
(really) working from home”3
“Compliance Is An Issue
For Remote Trading And
Investing Firms”4
Firms needing to “bend
the cost curve,” with
risk and controls a key
area of focus
Focus on exploiting
advances in artificial
intelligence (AI) and
analytics to reduce cost
to serve and increase
process quality
Continued regulatory
expectations on
conduct, consumer
protection and
cybersecurity
Prioritizing protection
of assets given market
turbulence
Seeking diversification
in investments to
mitigate risks (e.g., new
technologies)
Strengthening risk
management techniques
to reduce potential
trading and / or
transaction errors
Though ecosystem risk has been compounded, leading surveillance programs have opportunity to emerge with a healthier cost
base, a more holistic set of surveillance tools and new ways of working
1 https://www.wsj.com/articles/taking-notes-the-challenge-of-recording-trades-while-working-from-home-11585565630 3 https://www.washingtonpost.com/technology/2020/04/30/work-from-home-surveillance/
4 https://www.gfmag.com/magazine/april-2020/compliance-remote-trading-investing
Sources
Illustrative
2 https://www.globalbankingandfinance.com/will-the-virtual-trading-floor-become-the-new-reality/
Wall Street
Journal
Washington
Post
Harvard Business
Review
Global Banking &
Finance Review

4. Regulatory expectations regarding controlled access to information, surveillance and effective audit trails have remained broadly
consistent, though more complex to enforce in an era of virtual trading
AREAS OF FOCUS
Maintain communications within a controlled
environment, for example prohibit use of personal
devices and provide information security of non-work
standard communication platforms
Maintain complete and timely recordkeeping to
meet lookback analysis and heightened compliance
expectations (e.g., U.S. Consolidated Audit Trail) and
minimize paper-based notes and references
Enhance detection capabilities (e.g., use of video
surveillance or virtual reality) to detect potential
conduct risks
Use virtual barrier to detect MNPI data and
surveillance controls intended to block the exchange
of information between departments that may result
in business activities with conduct and / or legal risk
Implement and raise awareness of remote work
standards (e.g., pop-ups, online training) including
secure home network security settings and use of
data collaboration tools; review screensharing
protocols
REGULATORY
EXPECTATION
Recording of internal
and external trading
communications
Audit trail of
transactions
Control access to
material non-public
information (MNPI)
Restriction of access to
trading information
Appropriate due
diligence of
oversight and access
1
2
3
4
5
Monitor and implement detection, for example monitor
employees signing in to networks from personal devices or
abnormal locations, and inadvertent exposure of client
information to cloud-based applications (e.g., personal email)
Replicate the office environment, for example use face-to-
face video conversations in place of hands-on supervision,
and monitor trade execution instructions and client
communications to detect red flags as per business as usual
(BaU)
Use of advanced analytics techniques to parse alert flow
given the impact of market volatility, as well as to inform any
increase in the frequency of attestation processes
Close any potential gap of understanding with regulators by
using company proprietary trading applications to maintain a
digital record and remove paper trails, prioritizing date / time
of calls, location of calls, solicited bids / offers, etc.
Detect market manipulation, monitor and analyze trading and
market activity, such as voice, e-comm, and (P&L) information
to help detect insider dealing and misuse or disclosure of
MNPI
OPPORTUNITIES TO ADVANCE CAPABILITY
Regulatory Areas of Focus and Opportunities
Copyright © 2020 Accenture. All rights reserved.

5. Virtual trading environments amplify six key risks of misconduct, notably the threat of collusion and insider trading, with the
likelihood of regulatory lookback and testing of trade data raising the stakes for effective surveillance
Collusion and Schemes of Arrangement
Increase in unmonitored communication
among traders in chat rooms, as discussions
pushed from monitored media to less
frequently monitored channels (e.g., instant
messages)
Threat of Possible Fraud
During a downturn in the economic cycle, fraud
schemes such as market manipulation, pump-
and-dump, Ponzi schemes may increase due to
the pressure to maintain commissions
Potential Insider Trading Activity
A less frequently or consistently monitored
environment facilitates potential employee
engagement in higher personal securities transactions,
and market timing activities
Risk of Investment Suitability and Improper
Advice
Surveillance monitoring and “red flags” of
unauthorized trading in a non-discretionary
account, unauthorized transfers or uses of funds,
or placing a customer in unsuitable securities to
generate commissions
Inherent Risk level
With the potential for regulatory “lookback” and testing of trade data during periods of remote work, financial
organizations are re-evaluating their detection capabilities and supporting data and technology architecture
Inappropriate Client Relationship Management
Risk of investment professionals from engaging in off-
market transfers, not acting on behalf of client interests
and proper fiduciary responsibility, or not providing full
disclosures to clients of the impact of market activity
Copyright © 2020 Accenture. All rights reserved.
Elevation of Six Key Misconduct Risks
Unauthorized Discretionary Trading
Increased risk of an investment adviser
executing trades in a customer or investor’s
account without proper permission or
authorization

6. Transforming
Surveillance in an
Uncertain World

7. Four Potential Macro Scenarios
The near-future is still uncertain and firms should think about the possible impacts of four scenarios
1. Rapid Remission
The disease is contained,
and life returns to normal
swiftly. Government
measures work quickly to
stabilize the economy.
2. Flattened Curve
The rate of infections is
slowed but does not go
into remission. The
economy shrinks in near
permanent ways. Society
bends but does not break,
pulling together to sustain
government measures.
3. Cyclical Outbreaks
Infections are controlled
in past locations but
spread to new hot spots
and rebound in old.
Patience wears thin with
social distancing, opening
societal fissures.
4. Prolonged Chaos
Effects to control the virus
seem useless.
Governments and
societies are strained to
the point of breaking. The
economy is limited to
necessities only and
inflation soars.
Source: Accenture Research analysis.
7
Infection outbreaks due to uncooperative
elements
Non-compliance on two fronts
The rate of inevitable infections is slowedInfections are rapidly isolated until
absent

8. Bad actors don’t often leave a trail of evidence behind – in addition to technology solutions, surveillance
investigators require the right bank-wide processes in place to detect, respond, and resolve potential misconduct
Key Questions to Address
Key Questions To Address Leading Practices
Controls
Framework
Data
Technology
▪ How do supervisory officer behaviors and cadence evolve
to maintain oversight capability?
▪ What processes are required so that the surveillance
program is executed properly and continually improved?
▪ Clear definition of surveillance controls, processes, and
roles and responsibilities across the three lines of defense
▪ Ongoing tuning and review of compliance procedures on
false positives, suspicious behaviors target list and
changes to regulatory expectations
▪ What information is available and captured by
surveillance platforms or other tools?
▪ How can firms draw the right relationships between
available data points?
▪ Assessment of data integration for a 360 supervision by
integrating disparate data sources
▪ Business requirements and high data quality as baseline to
effectively execute surveillance complemented with AI
▪ What compliance tools are fit for purpose and what
accelerators may be required to monitor trading and
communication activities effectively?
▪ How can firms take advantage of disruptive and AI
capabilities to monitor trading activities in virtual
environment?
▪ Compliance ecosystem realignment and definition of
technology blueprint for both local and virtual trading
environments
▪ Design and implementation of surveillance policies
extending them to unsupervised and supervised machine
learning provided by proven technologies
8

9. Effective Surveillance Across the 3 Lines of Defense
Effective surveillance requires orchestration across the three lines of defense, with each needing to play their
role in mitigating misconduct risks such as collusion
9
Control Data Tech
1st Line Of Defense 2nd Line Of Defense 3rd Line Of Defense
Providing independent assurance of
operations and oversight groups
Executing trades per client direction and
within control parameters
Monitoring and enforcing guidelines and
identifying exceptions
▪ Is trading activity per customer guidelines?
▪ Are regulatory guidelines on best execution
being adhered to?
▪ Is there assurance on trading communication
surveillance?
▪ Were trade instructions recorded?
▪ Are digital trade communications available
for comparison to actual trade executions?
▪ How do we monitor so that employees are
not transacting client trade orders outside
of compliance monitoring protocols?
▪ Were there any gaps as per identified
client trade orders and executed prices?
▪ Was there an audit sampling conducted
on all client order program trades sent to
the trading desk for execution?
Key questions Key questions Key questions
Case Study: Supervisory Officer Case Study: Compliance Officer Case Study: Internal Auditor
✓ Establish escalation triggers across lines of
business (LOB)
✓ Implement LOB management controls
✓ Stand up supervisory LOB product teams
✓ Define key risk and performance indicators
(KRIs / KPIs) across trading desks
✓ Define surveillance rules and procedures
based on comprehensive list of misbehaviors
and risks in local and virtual environments
✓ Implement alert escalation process and red
flags to allow early identification of risk
✓ Identify team groups and relationships more
likely to act in collusion
✓ Assess escalated alerts, false positives
and missed cases for rule recalibration /
tuning
✓ Ongoing testing with new misbehaviors
due to a more virtual and digital
environment

10. EMPLOYEE
Personal
Account
Trading
Political
Contributions
Outside
Business
Activities
Large
Holdings
Voice
eComms
Social
Media
Video
Trade
Surveillance
Financial
Crime
Licensing
and
Registration
Remote Internet
Access
3rd Party
Access
Conflicts
Clearance
and Control
Room
Policies and
Training
Gifts and
EntertainmentBankruptcy
Filings
Private
Investments
Sub-
contractors
Conduct
Sales
Practices
HR Data
EXTERNAL
PARTIES
CLIENT
Holistic Surveillance for an Effective Detection
Effective mitigation of risks demands that compliance and control groups join the dots across a
number of interconnected parties and use cases
Control Data Tech
▪ The target state is an
effective integration of
data at scale from
multiple sources, across
product lines, portfolios
and geographies, and
using AI and machine
learning is helping global
banks create an “analytics
supply chain”
▪ Organizations are seeking
surveillance based on
data and analytics
platforms to serve up
connected and contextual
data across the enterprise
which can lead to more
informed answers, greater
insights and ability to
reconstruct entire trades
10

11. Controls Technology Blueprint
Leading financial institutions are allowing their technology estates to deliver the holistic surveillance required in
a virtual world through analytics, specialized applications and intelligent automation, and supported by an
advanced data processing core
11
Complex Event Processing (CEP) Engine
Big Data Core (e.g., Apache™ Hadoop®)
In Memory Analytics
Query Engine
CEP Cache Distributed Cache In-Memory DB
Workflow Alerts and Notification
HBase Data Storage on HDFS
Service Layer Interface
Internal and External Data Sources
Compliance
Portal
Employee
Portal
Management
Reporting
Regulatory
Reporting
Internal
Reporting
Analytics User Interface ( UI) / Dashboard UI (tablets / phone friendly)
Applications
Personal Account
Dealing App
Outside Business
Interest App
Gifts and
Entertainment App
Control Room
App
Policy and
Training Tool
Risk Assessment
Tool
Whistleblowing
App
Reg Change
Tracking Tool
Horizon Tracking
Tool
eComms
Surveillance
Audio
Surveillance
Social Media
Surveillance
Trade
Surveillance
Payment
Screening Tool
Sanctions
Screening Tool
KYC and PEP
Screening Tool
Suitability
Commentary
▪ Analytics UI provides flexible review
capabilities that allow selective / holistic views
and simple manipulation of aggregated data
through analytics (e.g., slicing of the
application output and sentiment analysis to
drive escalation)
▪ Specialized applications to transform
operational capabilities to execute functional
tasks to manage system / human workflow
integration
▪ An advanced data processing core underpins
the above functionalities and provides sufficient
storage to store all auditable evidence (e.g.,
surveillance applications identify sharing of
MNPI, with AI able to accelerate data mining
and understanding of relevant patterns)
▪ Intelligent automation to connect the dots to
provide insights across disparate data sources
and reduce manual processes related to data
aggregations (e.g., comms on clients’ orders
and bid-ask spreads across emails, instant
messaging, text messaging, social media, …)
Control Data Tech
KYC: Know Your Customer
PEP: Politically Exposed Person

12. Tactical turnarounds to extend
existing surveillance solutions
that require process and control
enhancements
Three Surveillance Transformation Approaches
The traditional way of operating in the Surveillance function has lagged on effective controls, data
management and technology which doesn’t cover short and long term business needs. Three transformation
approaches can change this trend
Enhance
Existing
Capability
Invest in
Proven
Techs
Integrate
Isolated
Functions
Address technology gaps to bring
notable advancements in
detection, investigation and
reconstruction surveillance
capabilities
360 supervision to reduce false
positives significantly and
improve proactiveness of the
Surveillance function to
anticipate misbehaviors or
misconduct risks
12

13. How can Accenture help?
Accenture is positioned to provide immediate support to help organizations respond to the virtual trading floor
implications from the pandemic crisis. Below are indicative areas where we can help
COVID-19 Banking: Navigating the human and business impact of COVID-19
Subject Matter Advisors “On Demand”: Support for regulatory assessment, industry benchmarking and change planning
Program Support: Dedicated team to assess, recommend and implement program enhancements
Service Delivery: Delivery of new surveillance methods as-a-service, with advisory support as appropriate
Challenge
Solution
Support
13
Control Reviews and Look Back
Existing monitoring controls are
typically not prepared to allow
remote working on an enterprise
scale and require “stress testing”
Provide support for:
➢ Technology architecture
review and planning
➢ Process and technology
control evaluation
➢ Remediation support
Platform Implementation and
Service Delivery
Analytics and more advanced
techniques (e.g., Virtual Reality) can
get de-prioritized in the move to
remote and focus on continuity
planning
Provide support for:
➢ Selection of preferred
vendor platforms
➢ Proofs of concept
➢ Implementation
➢ Service delivery
Regulatory Compliance
Validating conformance to
regulatory requirements during
remote working and confirming
procedures are in place to hold
traders to account
Provide support for
➢ Regulatory analysis and
recommendations
➢ Policy and procedure review
➢ Training updates

14. Contacts
Samantha Regan
Managing Director
Accenture Strategy & Consulting
Global Reg and Compliance lead
samantha.regan@accenture.com
Robimon Varughese
Senior Manager
Accenture Strategy & Compliance
Technology Lead - Reg and Compliance
robimon.varughese@accenture.com
Ben Shorten
Managing Director
Accenture Strategy & Consulting
Compliance & Privacy
benjamin.j.shorten@accenture.com

15. TRANSFORMING SURVEILLANCE
IN AN UNCERTAIN WORLD
About Accenture
Accenture is a leading global professional
services company, providing a broad range of
services in strategy and consulting, interactive,
technology and operations, with digital
capabilities across all of these services. We
combine unmatched experience and
specialized capabilities across more than 40
industries – powered by the world’s largest
network of Advanced Technology and
Intelligent Operations centers. With 509,000
people serving clients in more than 120
countries, Accenture brings continuous
innovation to help clients improve their
performance and create lasting value across
their enterprises. Visit us at
www.accenture.com
Disclaimer
This presentation is intended for general
informational purposes only and does not
take into account the reader’s specific
circumstances, and may not reflect the most
current developments. Accenture disclaims,
to the fullest extent permitted by applicable
law, any and all liability for the accuracy and
completeness of the information in this
presentation and for any acts or omissions
made based on such information. Accenture
does not provide legal, regulatory, audit, or
tax advice. Readers are responsible for
obtaining such advice from their own legal
counsel or other licensed professionals.