Trade Talk Blog: Surveillance

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In our previous two blog posts, Make Surveillance Smarter and Eliminate Blind Spots With TT Score and Supercharge Your Spoofing Surveillance with TT Score, we described how TT Score utilizes advanced machine learning technology to detect and score complex patterns of manipulative and disruptive trading activity, including but not limited to spoofing, layering, flipping, vacuuming and momentum ignition.

In this post, we will discuss the next phase of TT Score’s evolution, which is the integration of TT Score with the TT platform.

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This article was originally published by the National Society of Compliance Professionals. It was co-authored by Jay Biondo, Product Manager, Surveillance, Trading Technologies, along with James G. Lundy, Partner, and Nicholas A.J. Wendland, Counsel, both of Drinker Biddle & Reath LLP.

Trading Technologies’ TT Score is an ideal trade surveillance and compliance solution for detecting trading activities that could potentially be flagged as spoofing by regulators. By using machine learning technology, TT Score identifies patterns of behavior that may prompt regulatory inquiries so that quick corrective action may be taken before the activity becomes an issue for the firm.

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On January 29, 2018, the CFTC and the DOJ coordinated announcements regarding the filing of civil enforcement actions by the CFTC, naming five corporations and six individuals, and the filing of criminal actions by the DOJ against eight individuals (including six of the same persons named in the CFTC actions), for engaging in, or aiding and abetting, spoofing in the U.S. futures markets. The CFTC actions imposed fines ranging from $1.6 million to $30 million, which was the highest CFTC spoofing penalty to date. The announcement also marked the largest futures market criminal enforcement action in the history of the DOJ.

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There is nothing quite like the shot of panic you feel when you receive a letter from a regulator indicating that your trading activity, or trading activity that is under your purview, is being investigated for potential market abuse. These initial letters are usually just the prelude to a long process where the only certainty is that it will be expensive and time consuming regardless of the outcome. And now that prison time is on the table for certain malicious trading behaviors, the stakes have never been higher. In 2017, the CTFC tripled the amount of enforcement actions involving disruptive trading practices, levying tens of millions of dollars in fines and permanently barring traders from CFTC regulated markets.

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