The markets in which firms operate continue to expose them to new and emerging risk and control challenges. Our team helps clients navigate their way through these challenges using our deep technical, regulatory and industry expertise. We help them to build assurance and restore confidence in their risk and control frameworks.

In doing this, we work with clients across the three main areas of a market lifecycle:

(1) Market Disturbance, (2) Market Reform and (3) Market Confidence. While some of these areas will naturally overlap, we make sure we bring all our expertise with us, working across the full lifecycle when we help our clients in the Middle East.

(1) Market Disturbance
 

In certain industries, market disturbance events (everything from large trading gains to losses inappropriately caused by both humans and algorithms), are becoming all-too common. The financial services sector has itself had its fair share of issues since the financial crisis, but one only has to look at issues in the automobile, energy, media, aviation and other industries to observe similar issues and risks.

Drivers for such events, include misconduct, market manipulation, new technology emergence and operational risk related control issues. Their impact may be to cause disputes and litigation, regulatory enforcement and new regulation, or even the need to address issues related to governance and accountability. But whatever their cause or effect, the outcome is normally the same: increased scrutiny from both internal and external stakeholders across markets.

It’s why in this area of the market lifecycle, we have assisted clients by advising as part of litigation and disputes, acting as Expert Witnesses, as well as conducting investigations and root-cause analyses for both regulators and management. Much of our focus to date has been around issues that surface in the wholesale and retail banking markets, helping both financial and non-financial services firms.

(2) Market Reform

Disturbances may cause markets to reform and evolve naturally, or they may be required to reform due to external intervention. Whatever the reason, when a market reforms, any business operating within it will most likely need to adjust their systems, processes and controls to comply with any new market norms or
regulatory requirements. This is especially so, as some market disturbance may
also reveal specific weaknesses in governance and control frameworks that
require further risk assessment and remediation.

We have assisted clients with recent market reform events such as the implementation of new regulation, as well as responding to specific regulatory enforcement orders requiring enhancements to market conduct risk control frameworks. Our work often focuses on helping clients understand the changes required in both business and support functions. Because our work is often focused on helping clients understand the change that is required in their business and support functions, our mission is to always set this out clearly and transparently.

We have also focused on the growing area of wholesale market codes of conduct, and recent guidance and supervisory statements around algorithmic trading. Being market-focused, many of these topics cut across different industry sectors, and so our client outlook spans both financial services and corporate institutions.

The purpose of any market reform should be to restore confidence in the market and to demonstrate that the issues within it have been fully addressed. It’s why the key objective for many companies who have been through market disturbance and market reform events is to regain confidence in their systems, processes and controls to a level that is ‘fit for audit’. 

We create confidence by undertaking specific reviews and analysis, either by working alongside management or as part of Internal Audit. In certain cases, we’ll also work through the provision of third-party independent assurance – for example providing a Deloitte report under an internationally recognised framework such as International Standards for Assurance Engagements (ISAE).

In this area we can provide clients with independent assurance over benchmark control frameworks (such as LIBOR). We can also conduct thematic control reviews across areas including sales and trading conduct controls, conflicts of interest management, fraud controls, algorithmic trading controls and many others.

Since the Financial Crisis the level of regulatory scrutiny on financial institutions’ conduct has increased significantly, with regulations focused on protecting clients, increasing market transparency and facilitating competition in the market. 

We help our clients to achieve regulatory compliance by providing advice and support on how to address conduct related regulatory requirements, respond to regulatory change, remediate issues and implement major structural changes to their businesses. 

Our diverse team includes industry practitioners, accountants, and treasury and capital markets professionals, collaborating to help companies achieve compliance across a range of prudential regulatory and treasury-related areas.

We advise on the practical impact of regulatory change on Banking and Capital Markets companies, including:

• Regulatory compliance – Achieving ongoing compliance with prudential and conduct rules, preparing for PRA and FCA supervisory reviews.
• Remediation work – Remediating issues for clients raised during PRA/FCA and ECB supervisory reviews.
• Regulatory change and implementation support – Assisting clients to analyse the impact of upcoming regulatory changes and implement regulatory change programmes across business lines and functions.
• Major structural change – Assessing the regulatory and commercial impacts of structural change on clients’ businesses, including acquisitions, disposals and restructuring.
• Recovery and resolution – Assessing and enhancing existing recovery plans and supporting activities to enhance resolvability.
• Securitisation – Advising on significant risk transfers, compliance with STS rules, performing investor due diligence, and optimising CLO risk retention and capital requirements.

There is increasing pressure on financial institutions from both internal and external stakeholders to put client assets protection at the heart of their business objectives. We support management teams in achieving this goal using our broad range of professional services solutions, underpinned with deep industry experience of our Client Assets CASS regulatory knowledge.

 We work with a wide range of financial institutions from the incumbents in the capital markets, retail and wealth management sectors, to the FinTech disruptors such as crowdfunding and peer-to-peer platforms, offering design and implementation solutions through to monitoring and remediation.

Our services include operating model design and validation, Internal Controls Assurance and CASS audit, and CASS regulatory interpretation and insights.