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Dear FCA

Dear Simon Walls, Head of Wholesale Markets Department, Financial Conduct Authority

I received your letter reflecting the FCA’s view that firms have not kept pace with regulatory reform and therefore warning them to take significant action in order to avoid potential penalties for noncompliance. I am writing to you as the Principal of UK Brokers International, a financial firm that has integrated cutting-edge technology into its compliance solutions suitable to meet the demands of the reform.

Compliance Opportunities

I don’t have to tell you that financial institutions manage and control electronic communication data to meet regulatory requirements. Fortunately, with the latest technology available, we can achieve this without impacting operational performance. We have recently started working with Shield. Since then, we have achieved and maintain significantly higher levels of compliance within many regulations concerning eComms and Surveillance. Allow me to elaborate.

Shield’s technology improves compliance efficiency by reconstructing omnichannel communication chains with an advanced multi-layered correlation analytics engine. Shield’s machine learning technology then leverages the data links made within the eComms to connect interactions throughout each transaction. This ensures that regulated data is fully searchable and promptly retrievable enabling investigation capabilities in a timely manner. Shield was uniquely designed to address compliance needs. In addition, UK Brokers International selected Shield as their compliance solution provider as they have been recognized and rewarded for their work focused on trade reconstruction solutions, compliance with cross-regulation requirements, and enabling organizations to highlight regulatory compliance efficiently.

We certainly understand that the Senior Managers Regime (SMR) is an increasingly important component of the financial regulatory structure in the United Kingdom. To help support the transparency of this demand in the regulatory space, we have deployed a compliance platform that offers complete visibility for senior management to have the right controls in place while also optimizing the compliance work lifecycle.

A Cross-Regulation Approach

We believe that installing this proactive-like technology at our firm leads to thoughtful and purposeful governance driving decision-making processes around a business that values a culture of good conduct. Today’s financial institutions need to capture, archive, and protect every single interaction for a prescribed period. But the real challenge begins when various regulatory requirements address different aspects of our business. Installing Shield provides us with the ability to address cross-regulatory requirements. A good example of that is our firm’s ability to prepare for ePrivacy’s meta-data requirements even today, long before the regulation is officially launched.

Fighting Key Drivers of Harm

MiFID II is approaching its second-year anniversary, along with new regulations to come, a large proportion of firms remain out of compliance with the rule’s extensive requirements. However, enterprise software providers are only just now are building advanced technological tools that regulated firms such as ours need to achieve compliance with increasingly complex regulations while still managing diverse teams and running day-to-day operations.

While we appreciate the Regime’s diligence in working to ensure compliance with the EU’s latest financial reforms, UK Brokers International also must bring to light the extensive efforts we have undertaken to conform to the requirements of MiFID II, GDPR, MAR, and other international regulations that apply to the financial services we provide. By utilizing the compliance and data platform solutions available to the regulated community today, we can operate with higher confidence that we are compliant with existing regulations and ready for new regulatory developments in the future.


Monica Helsman, Principal at UK Brokers International


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