The FCA has made surveillance a top enforcement priority for 2025, with Therese Chambers warning firms that market abuse controls must be ‘predictable, proportionate, and purposeful’.
Recent statements and the 2024 Suspicious Transaction and Order Reports (STORs) report show a renewed focus on insider dealing, organised crime, and cultural accountability.
This aligns with the regulator’s broader five-year strategy, which prioritises market integrity, data-led supervision, and more assertive enforcement.
At the same time, investor scrutiny of integrity, governance, and data transparency continues to rise—especially as high-profile enforcement cases make headlines.
With pressure from both regulators and investors, firms must demonstrate more than just intent to look for suspicious trading activity. They’re expected to show operational readiness—from comprehensive surveillance and escalation workflows to documented governance and cultural alignment.
Five Core Expectations
- Full trade coverage: Surveillance must cover all asset classes, including less liquid and over-the-counter instruments. This includes all order and execution records.
Red flag: Limited coverage may allow manipulation to go undetected.
- Communication monitoring: Firms must monitor emails, chats, voice calls, and collaboration tools for potential leaks or misconduct.
Red flag: Gaps in capture or analysis raise cultural and compliance concerns—especially if tools are not tested regularly for effectiveness.
- Integrated escalation and STOR workflow: Firms should have a seamless process from alert review to documented escalation and STOR filing.
Red flag: Weak audit trails and lack of thematic and trend analysis—even on near misses—can undermine FCA interactions.
- Expert network oversight: Interactions with expert networks must be controlled and monitored to mitigate insider risk.
Red flag: Unmonitored calls and research discussions significantly increase enforcement risk.
- Culture of Accountability: Surveillance is not just about technology—the FCA expects a culture that supports escalation and upholds market integrity.
Red flag: Silence or inaction on risk signals can point to governance breakdowns. Is your surveillance program ready for scrutiny?
How We Help
Meeting surveillance expectations requires more than just technology—it takes an integrated framework that combines controls, culture, and expertise. We help firms align regulatory expectations with operational reality, supporting everything from governance to intelligent surveillance and reporting.
Our regulatory advisory and surveillance solutions help you close compliance gaps and build a programme that’s both regulator-ready and investor-trusted. Our offerings include:
- Surveillance Technology: Trade and communications surveillance across multiple asset classes and channels, delivered through ACA’s ComplianceAlpha® platform with risk-based alerting and integrated oversight tools.
- Market Abuse Risk Assessments: Evaluations tailored to your firm’s specific risk profile, designed to uncover gaps in your control environment and inform mitigation strategies.
- STOR Process Reviews: End-to-end assessments of your escalation and reporting workflows to ensure FCA alignment, including proper documentation of near misses.
- Expert Network Oversight: Monitoring of high-risk research interactions using AI-powered insights and human chaperoning to help reduce insider risk.
- Governance and Culture Support: SM&CR readiness, training programmes, and mock exams to embed a culture of accountability and demonstrate effective control to regulators.
- Transaction Reporting: Monitoring and analysis to ensure your regulatory reports align with surveillance outputs, delivered through our ARRMA (ACA’s Regulatory Reporting Monitoring and Assurance) service.
Contact us to learn how our UK regulatory experts and advanced surveillance technology can help safeguard your firm and investors.