Security, data and compliance in Trade Surveillance & Market Abuse Monitor

How Trade Surveillance & Market Abuse Monitor protects data and supports your compliance obligations.

Security controls

Single sign-on

Employees and compliance staff sign in through your identity provider, so your password and multi-factor policies apply.

Role-based access

Employees see only their own records; reviewing an exception is separate from approving a sanction.

Confidential lists

The watch list is visible only to the roles you choose. Employees see whether a request is approved, not why a security is on a list.

Encryption and keys

Client data is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.

Complete audit trail

Every view, change, decision and export is logged with the person and time, and cannot be edited.

Data residency

Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Requirements it supports

• SEC Rule 204A-1 under the Investment Advisers Act (Code of Ethics)
• Rule 17j-1 under the Investment Company Act
• Investment Advisers Act Section 204A and Exchange Act Section 15(g) (misuse of material nonpublic information)
• SEC Rule 10b-5 under the Securities Exchange Act
• FINRA Rule 3210 (accounts at other broker-dealers and financial institutions)
• FINRA Rule 3110 (supervision)

The product supports these requirements; meeting them remains your organization's responsibility.

Where it runs

• Moraph cloud: Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for firms outside the US.
• Dedicated environment: A single-tenant environment for firms whose policies require isolation, scoped in the proposal.
• With a managed service: Optionally run alongside a Moraph managed service for broker feed management and platform administration.

Limitations

• The Monitor flags patterns for review; it does not decide that insider trading or front-running took place. Your compliance staff make that judgment and record it.
• Monitoring covers employee personal trading under a Code of Ethics. It is not a market-wide surveillance system for client or proprietary trading on exchanges.
• Results depend on brokers providing complete and timely feeds or statements, and on employees declaring their accounts.
• Comparison with firm and client trading requires order and execution data from your order management system.
• It does not review employee communications. Email and chat surveillance needs a separate archiving and review tool.
• Gifts, entertainment, political contributions and outside business activities are not included.
• It does not file regulatory reports or make referrals to regulators; those decisions and filings are made by your firm.
• Rules are configured from your Code of Ethics; changing the Code and its rules is your firm's decision.