By Lawrence Deju – Wiseman, Head of RegTech Solutions
Trade surveillance is no longer a post-hoc compliance function. For financial institutions operating across borderless markets, it has become core infrastructure. In our latest blog, Lawrence Deju-Wiseman, Head of RegTech Solutions at GTN, explores why effective trade surveillance cannot just be a post-trade module tacked onto a system, rather it must be inextricably linked to how orders move through the system.
Regulator expectations
Every regulator with whom we hold a licence-from the DFSA to MAS, from FCA to HKMA-codifies the same fundamental expectation: firms facilitating market access must actively monitor for abuse.
Laurent van Burik, Chair of IOSCO’s Assessment Committee, was direct in the 2025 Thematic Review: regulators must ensure they have adequate and up-to-date tools for effective market surveillance.
MAS mentioned market misconduct remains one of its “evergreen” enforcement priorities, with 58 market abuse investigations conducted in its most recent enforcement report issued in April 2025.
The infrastructure problem
Market abuse erodes public confidence in capital markets and discourages participation. It fundamentally harms the markets, businesses, clients and society at large.
Monitoring a single market for a single asset class is already demanding. Monitoring over 90 markets across 8 asset classes, spanning jurisdictions from Singapore to the United States, with order flow that can cross multiple regulatory regimes in a single transaction is a fundamentally different problem.
Requirements don’t only vary by regulatory regime; they also vary by asset class, sub-product and venue.
The reality of cross-border flows
Consider an example: a Bahraini broker transmits an order on behalf of their end-user, a German national, through a DFSA-regulated entity. This order, for Japanese equities, is transmitted across global execution management systems, passes through to a MAS-regulated entity, then sent downstream to an executing broker. Moments later, partial fill data is passed back through the chain all the way back to the end-user. Meanwhile, surveillance systems consume the order and trade data, along with relevant market data and historical context, identify an anomaly and escalate it to analysts for review.
Diagnosis: why firms fail
The difficulty is not raw volume. The most common point of failure is when firms do not build surveillance tooling which is deeply integrated into their infrastructure.
Surveillance, the data flows that underpin it, and the analyst teams that investigate it must be part of the trade workflow. When surveillance runs separately from order and execution data, the entire process cannot sit as part of a global integrated trading tech stack. Rather than operating as a post-hoc module, the surveillance function must be inextricably linked to how orders move through the system.
What effective surveillance requires
Alerts are a starting point. What determines the quality of a surveillance programme is the quality of the alerts and the investigation process that follows.
This includes the depth of data available to the analyst, the rigour of the review, expertise of the surveillance team and the seniority of the individuals making decisions.
Investigative analysts need access to a rich data environment: order and execution records, client profiles, market conditions, securities holdings and transfers history. They must be trained to look beyond the individual alert and assess related activity across asset classes, venues, and time periods to identify patterns that a narrow review would miss.
This work must be conducted hand-in-glove from analyst to Global Head to CCO to engage with the substance of cases and investigate every matter to ensure that regulatory and market integrity obligations are met.
Surveillance as systemic infrastructure
It is easy to see how high-touch processes like surveillance could be misunderstood as a regulatory burden to be discharged with a priority on cost-efficiency rather than effectiveness. We cannot take that view.
The firms we serve at GTN are themselves operating under regulatory scrutiny. Their regulators expect due diligence over the infrastructure partners and intermediaries whom they rely on. When they route order flows through infrastructure, they are placing trust in the controls environment, not just the trading technology. That trust is not incidental to the relationship. It is the relationship that is core.
As a broker-dealer in a number of jurisdictions, we must preserve the integrity of capital markets which our clients look upon us to uphold.
The systemic shift
Brokers, exchanges and regulators are not shy about withdrawing market access to those that they no longer trust. Robust surveillance demonstrates trustability and ensures continuity of client access to liquidity.
The firms we serve-fintechs, brokerages, and wealth managers-are themselves operating under regulatory scrutiny. Their regulators expect due diligence over the infrastructure partners and intermediaries whom they rely on. When they route order flows through our systems, they are placing trust in our controls environment, not just our trading technology. That trust is core to the relationship.
Regulatory references
IOSCO, “Thematic Review on Technological Challenges to Effective Market Surveillance,” February 2025
Monetary Authority of Singapore, “Enforcement Report 2023/2024,” April 2025