Inside the AFME 2025 Surveillance Panel: Data, Culture, and AI’s Reality Check 

Surveillance begins and ends with a set of controls meant to capture a risk program. But as those risks and how we monitor them evolve, how do effective controls meet the moment? At the panel I hosted at AFME’s European Compliance and Legal Conference, “Spotlight on Surveillance,” regulators, practitioners, and compliance leaders agreed that surveillance has entered a new phase. One that’s more data-driven, interconnected, and reflective of real-world behavior.  

The Financial Conduct Authority (FCA), the Dutch Authority for the Financial Markets (AFM), StoneX, and Shield came together to talk openly about where surveillance is headed. The conversation was refreshingly candid—sometimes critical, occasionally cautious, but always forward-looking. 

What emerged was a thoughtful discussion on the evolving interplay between data, culture, and technology. Including practical ways firms can strike the right balance between them. 

Data Governance in Surveillance 

The regulators didn’t mince words: Too many firms still treat data like running water. You turn the tap, and of course it flows. Except in surveillance, it doesn’t always. And as a compliance leader, it’s your responsibility to know. 

Robert Mangham, Technical Specialist at the FCA put it bluntly, “Having the model working is not enough. If the data doesn’t feed into it, the engine stops.” 

I also chimed in sharing: “Not too long ago, the focus was always on the controls…but now, the quality of the data is just as critical as the controls themselves.” 

The message landed: Data governance isn’t a background process anymore. It’s the fuel, and without it, the machine grinds to a halt. 

Shared Accountability Between IT and Compliance 

If data is the fuel, who’s responsible for making sure it’s fit for purpose? The answer: everyone. 

Robert drew the dividing line: Data producers bring it in, data consumers use it—but both must verify it. Surveillance teams can’t simply shrug and say, “IT handles that.”  

Mark Cross, Director of Central Compliance at StoneX added a critical nuance, “Surveillance is as much a compliance issue as an IT issue—both must work in harmony, but both have responsibilities.” 

That harmony is still a work in progress at many firms. But the direction is clear: Accountability has to be shared across the chain if surveillance is going to work. 

Culture and Non-Financial Misconduct in Compliance 

If data is the technical foundation, culture is the human one. And culture, as the panel made clear, is inseparable from compliance. 

Robert was direct: “Poor firm culture that allows misconduct is more likely to see fraud and market abuse.” 

Mark emphasized the practical side: Small things matter. “Jump on the minor violations—missed attestations, poor comms—and you can often prevent the bigger issues.” 

It’s a reminder that culture isn’t abstract. It shows up in chat logs, in meeting behavior, and in whether people take their obligations seriously. Ignoring the “small stuff” is a shortcut to bigger problems. 

AI in Surveillance: Hype vs. Impact 

The conversation eventually landed where all compliance conversations do these days: AI. But the tone was refreshingly skeptical. 

Mark set expectations: “AI isn’t a switch you flip—you’re tied into contracts for years.” 

I reinforced the principle, “AI has to be measurable, tested, and better than what came before, not just hype.” 

Rob added the practical payoff, “The value is freeing humans from false positives so they can focus on deeper investigations.” 

The consensus was clear: AI has a role to play—especially in triaging alerts and comms surveillance—but it’s not replacing analysts. It’s a tool in the toolbox, not the whole program. 

Real-Time Dashboards and Innovation Beyond AI 

AI dominated the conversation, but it wasn’t the only theme. The panel pointed to innovations that are less flashy but often more impactful. 

Rob shared how dashboards and real-time monitoring insights are transforming monitoring. “Real-time dashboards let you see problems as they emerge—far better than static quarterly reports.” 

I tied it back to data, “On the other side of strong data controls are good dashboards and visualizations—that’s what makes surveillance work.” 

Meanwhile, regulators pointed to cross-border collaboration and convergence as another form of innovation—one that builds resilience across the entire industry. 

The lesson? Innovation isn’t just about new algorithms. It’s about working smarter, faster, and together. 

Conclusion 

The Spotlight on Surveillance panel left no doubt: Surveillance continues to evolve. 

Data integrity cannot be assumed. Accountability is collective. Culture is compliance. AI is useful, but only when grounded in reality. And innovation beyond AI should not be overlooked as it remains a place where many real improvements can be made. 

The future of surveillance won’t be defined by a single tool or technology. It will be defined by how well firms balance people, process, and technology in practice. 

Because at the end of the day, as I shared: “We started with data, and we end with data.” 

If you’re ready to move beyond static reports and hype-driven tools, connect with our team to see how Shield powers effective, future-ready surveillance.