Real-time moderation, message blocking, ethical walls, and feature controls across all communications channels
Preserve conversational context of any form of structured or unstructured data
Built to scale, with lightning fast ingestion, search, and export performance
Ingest voice and other content sources with full APIs to aggregate with trade data and analytics apps
Actiance’s modern content store and robust supervisory capabilities are complemented with a complete set of APIs to power trade reconstruction and behavioral analysis tools. This allows firms to marry communication activities with financial transactions for a comprehensive MiFID II surveillance platform to simplify the process of supplying regulators with all the communications associated with a specific trade activity.
Tamper-proof, WORM-compliant storage ensures that records are maintained immutably on a durable medium that cannot be altered or deleted, but remain searchable and readily available upon request. Multi-layered data protection controls include encryption in motion and at rest, authentication, key management, and security across hardware, networking, storage, and infrastructure. Operational, management, and security controls are backed by SSAE-16 SOC II attestation by an independent auditor.
Robust supervisory review capabilities enable firms to establish and enforce policies and procedures to ensure that managers, employees, and agents comply with the MiFID II directive. Firms can demonstrate effective oversight and control over the firm’s communications by reviewing conversational context of communications occurring within and across 80+ communications networks. Actiance enables random sampling and lexicon-based policies that can be defined globally or specific to each network, location, group, or supervised user to reduce false positive rates. Configurable supervisory workflows and escalation paths provide flexibility to meet centralized and de-centralized review models, while complete reporting ensures that MiFID II reporting obligations are met.
Forensically-sound capture of records, in context, across multiple communications channels including email, instant messaging, voice, collaboration apps, and social media related to the reception, transmission, and execution of client orders. Actiance's TrueCompliance™ capture ensures the preservation of full binary records, preservation of message order, and the capture of hash values for robust defensibility. Granular policy management ensures that records can be made available for 5 years for clients and 7 years for regulators. Sustainably fast search and export ensures that records are readily available for any regulatory request.
Actiance allows financial services firms to meet record keeping, retention, storage, and supervisory requirements of MiFID II / MiFIR with an integrated platform that captures and preserves 80+ communications channels, which can then be harnessed to understand investor communications leading to trade events. Vantage and Socialite provide forensically-sound compliant capture and Active Compliance controls, while Alcatraz enables the immutable storage and supervisory review of conversations in context. Open APIs enable communications to be aggregated with trade data from full reconciliation of trade events to meet MiFID II / MiFIR requirements.
“We are likely to see a historic shift on how assets are being managed and invested, as our distribution partners are changing both their product preferences and their use of technology to adapt to these rule changes. ”Larry Fink, Chief Executive of BlackRock (Financial Times 1/26/2017)
Originally implemented in 2004, the Markets in Financial Instruments Directive (MiFID) was original designed to increase competition and investor protection in financial investment products. While MiFID served to provide harmonization of financial market operations across member EU states, it failed to deliver the investor protections that became exposed during the 2007 financial crisis. The limitations of MiFID included 1) the creation of new derivative financial products, 2) the participation of a broader set of investors that are active in the market, and 3) new communications tools used to market and sell financial products.
MiFID II and its accompanying regulation outlined in the Markets in Financial Regulation (MiFIR), attempt to create greater market transparency, a ‘level playing field’ for investors large and small, and a broader set of communications that lead to a trade event. MiFID II is very comprehensive with over 90 articles in total addressing market operations, investor protection, record keeping, supervision, information storage, as well as other reporting obligations. MiFID II regulations require that financial services firms capture and preserve all communication forms, including email, voice, records of face-to-face communications, social media, etc. that directly relate and lead up to a financial transaction. MiFID II regulations require that the information be stored immutably for 5 to 7 years in a format that allows for the fast retrieval and search of those communications. Once those communications have been stored, firms need to associate them to trade events as part of a reconstruction process, in order to ensure that firms have met all applicable MiFID II regulations.
MiFID and MiFID II requirements create a number of technology, process, and infrastructure challenges for financial services firms. MiFID requirements are aimed at providing better investor protection, ensuring that markets are operating efficiently and transparently, and reflect the unique challenges created by new financial products and new communications tools in use in the marketing and sale of financial products. MiFID requirements include the need to capture all communications that are associated with a trade event, which can include traditional channels including email, but now must also including voice recording, and a variety of financial networks and messaging apps including Symphony, IceChat, Thompson Reuters, Bloomberg, Slack, Skype for Business, Cisco Jabber, and others. MiFID requirements for capture of this breadth of communications sources will cause firms to re-evaluate their ability to preserve those content sources via custom built approaches or through native access to each communication network.
MiFID requirements include the need to capture all communications that are associated with a trade event, which can include traditional channels including email, but now must also including voice recording, and a variety of financial networks and messaging apps including Symphony, IceChat, Thompson Reuters, Bloomberg, Slack, Skype for Business, Cisco Jabber, and others. MiFID requirements for capture of this breadth of communications sources will cause firms to re-evaluate their ability to preserve those content sources via custom built approaches or through native access to each communication network.
MiFID requirements for the retention and storage of these sources entails the assignment of retention policies to each network, the immutable storage of that content, as well as the use of a storage technology that enables the fast search and retrieval of that content. Supervision is also a key MiFID requirement, to ensure that firms are conducting review against all communications sources to ensure adherence to MiFID II and MiFIR mandates.
Finally, supervised communications will need to be associated with a trade event to perform trade reconstruction to meet MiFID requirements.
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