Surveillance Program Gap Analysis Checklist


Peter Kenny

Publish Date



  • ComplianceAlpha
  • Compliance
  • eComms Surveillance
  • Trade Surveillance

Regulators have shifted their focus to different aspects of surveillance programs at different points in time, depending upon what generates the biggest risk at the time.

  • Over the past two years, we have seen the SEC and other U.S. regulators issuing record-breaking fines for books and records issues related to the increased use of off-channel communications.
  • In the post-pandemic era, the FCA focused on market abuse concerns as a result of a volatile market. Additionally, the FCA further emphasizes the importance of firms monitoring for non-financial conduct.
  • The SEC has also set its sights on the use of MNPI, and has even gone so far as to redefine the term with the introduction of shadow trading.

While the regulatory focus may be dependent on the current risk environment, it is hard to predict how that environment might shift, and the regulatory repercussions from those changes. Firms globally need to establish and maintain a robust surveillance program to make sure they are ready for what may come and compliant with the current regulations.

We have updated our Surveillance Program Gap Analysis Checklist to help you establish or update your surveillance program to meet current regulatory requirements. Download our checklist to ensure your surveillance program can weather changing the risk environment.


How we help

ACA’s integrated surveillance solutions are designed to help your firm manage its firm-wide conduct and regulatory risks in a way that meets expectations and industry best practices. Our offerings include consulting, managed services, and technology to provide a holistic solution for developing and executing a comprehensive and truly risk-based surveillance program.

For questions or to discuss how ACA can help your firm strengthen its surveillance program, increase efficiencies through technology, and ensure your regulatory obligations are met, reach out to your ACA consultant or contact us here.