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THE MANY CHALLENGES
OF INFORMATION
SHARING
Recently the Financial Industry Regulatory Authority hit
independent broker-dealer Cambridge Investment
Research and Merrill Lynch with fines totaling $850,000 for
failing to properly supervise employees who were involved
in the sale of mutual funds, and not properly monitoring the
exchanges between retail marketers and exchange-traded
note traders.
Notably, although Merrill Lynch did have a flagging system
in place, built around a general lexicon search, it reportedly
didn’t have sufficient reviewing practices organized —
including no process for escalating reviews of private-
public side communications that contained potential
material information, or for enforcing required measures for
separating traders and marketers in the global wealth and
global banking and markets divisions.
Building the Chinese wall
This highlights a major challenge when it comes to
compliance — particularly when it comes to the public and
private side employees in financial institutions. The problem
comes down to the fact that financial services firms
frequently receive and handle information that counts as
confidential or “insider” information (also known as MNPI –
or Material Non-Public Information). Traders or other
agents who possess material information that has not been
made public are prohibited from sharing it with others who
do not have a need to know, even when they may be
working on different sides of the same overall organization.
To maintain this divide, firms must erect information
barriers around proper control of the flow of non-public
information from one department to another. This is
frequently called a Chinese wall, or informational firewall,
referring to a virtual barrier that’s in place to stop the
exchange of information that could result in illegal or
ethically dubious activities.
The concept of Chinese walls has existed since
the 1929 stock market crash when Congress
first seriously discussed regulatory barriers
separating investment bankers and brokers.
However, the need for such divides has greatly
increased over the past couple of decades,
following the enacting of the Gramm-Leach-
Bliley Act of 1999 (GLBA). This law, which
helped empower many of today’s biggest
financial powerhouses, repealed previous
regulations that stopped firms from carrying
out combinations of investing, banking, and
insurance services.
A brief history of informational
firewalls
Failing to maintain this informational divide can
lead to some devastating consequences for
financial institutions. In 2003, the Securities and
Exchange Commission (SEC), National Association
of Securities Dealers (NASD), New York Stock
Exchange (NYSE), and other regulators announced
that they had agreed a massive $1.4 billion
settlement with 10 Wall Street firms for failing to
mitigate against these conflicts of interest. Two
well-known analysts were fined and given lifetime
bans from participating in the securities industry.
Among the stipulated changes were strengthened
commitments to separate divisions within banking,
to carry out extra-stringent monitoring and more.
A brief history of informational
firewalls
Today’s firms must be diligent in their
stance on information sharing, ensuring
that this happens only where absolutely
required and lawful. As the Merrill Lynch
example shows, having protective
measures in place when it comes to
monitoring isn’t enough.
Lexicons, referring to a simple keyword or
phrase searches, are massively outdated
tools that can cause more problems than
they solve. Lexicons yield a massive
number of false positives (FPs), inundating
system operators with high numbers of
erroneous flagged messages, making them
virtually valueless.
At Shield, we know that the world of
detection doesn’t stay still. It’s not
enough to simply set up lexicon-based
models and hope that they will catch
any potentially violating behavior that’s
thrown at them.
With that in mind, we continually add
to, modify, and otherwise improve the
detection models we used to provide
updated coverage regarding the latest
risk areas, along with new products,
areas of business, mandated lines, and
comments from regulators.
Have the right tools in place
Have the right tools in place
This improves the relevance of alerts, cutting down FPs,
while also detecting infringements that regular lexicon
searches or AI-only systems will miss. The technology
we have developed is able to detect any hints in
conversations between traders — or any other
personnel requiring oversight — to identify when a
potential breach is taking place. We are even capable
of building models able to analyze complex interactions
when two people are speaking in two territories with
different regulations. This is a major problem and
challenge in global operations.
By knowing the employee department, job,
management line, and other relevant information,
Shield constructs specialized models to surveil
specifically the eComm interactions between different
groups of employees like traders and marketers within
its global wealth and global banking and global
banking divisions. We combine new age lexicon
technologies, along with the latest AI innovations, to
provide the best quality surveillance system of eComms.
Regulations separating the two sides of
financial institutions are only going to get
more stringent as time goes on. Fines are
being handed out with increasing
regularity — and merely paying lip service
to detection through the installation of
outdated detection tools isn’t enough.
Firms must ensure that not only do they
have a strong informational firewall in
place but that they also have the
detection tools present in case someone
on either side finds a way over it.
Contact Us
Phone Number
97235685587
Email Address
info@shieldfc.com
Website
https://www.shieldfc.com/
Thank You
https://www.shieldfc.com/

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The Many Challenges of Information Sharing - Shield

  • 1. THE MANY CHALLENGES OF INFORMATION SHARING
  • 2. Recently the Financial Industry Regulatory Authority hit independent broker-dealer Cambridge Investment Research and Merrill Lynch with fines totaling $850,000 for failing to properly supervise employees who were involved in the sale of mutual funds, and not properly monitoring the exchanges between retail marketers and exchange-traded note traders. Notably, although Merrill Lynch did have a flagging system in place, built around a general lexicon search, it reportedly didn’t have sufficient reviewing practices organized — including no process for escalating reviews of private- public side communications that contained potential material information, or for enforcing required measures for separating traders and marketers in the global wealth and global banking and markets divisions.
  • 3. Building the Chinese wall This highlights a major challenge when it comes to compliance — particularly when it comes to the public and private side employees in financial institutions. The problem comes down to the fact that financial services firms frequently receive and handle information that counts as confidential or “insider” information (also known as MNPI – or Material Non-Public Information). Traders or other agents who possess material information that has not been made public are prohibited from sharing it with others who do not have a need to know, even when they may be working on different sides of the same overall organization. To maintain this divide, firms must erect information barriers around proper control of the flow of non-public information from one department to another. This is frequently called a Chinese wall, or informational firewall, referring to a virtual barrier that’s in place to stop the exchange of information that could result in illegal or ethically dubious activities.
  • 4. The concept of Chinese walls has existed since the 1929 stock market crash when Congress first seriously discussed regulatory barriers separating investment bankers and brokers. However, the need for such divides has greatly increased over the past couple of decades, following the enacting of the Gramm-Leach- Bliley Act of 1999 (GLBA). This law, which helped empower many of today’s biggest financial powerhouses, repealed previous regulations that stopped firms from carrying out combinations of investing, banking, and insurance services. A brief history of informational firewalls
  • 5. Failing to maintain this informational divide can lead to some devastating consequences for financial institutions. In 2003, the Securities and Exchange Commission (SEC), National Association of Securities Dealers (NASD), New York Stock Exchange (NYSE), and other regulators announced that they had agreed a massive $1.4 billion settlement with 10 Wall Street firms for failing to mitigate against these conflicts of interest. Two well-known analysts were fined and given lifetime bans from participating in the securities industry. Among the stipulated changes were strengthened commitments to separate divisions within banking, to carry out extra-stringent monitoring and more. A brief history of informational firewalls
  • 6. Today’s firms must be diligent in their stance on information sharing, ensuring that this happens only where absolutely required and lawful. As the Merrill Lynch example shows, having protective measures in place when it comes to monitoring isn’t enough. Lexicons, referring to a simple keyword or phrase searches, are massively outdated tools that can cause more problems than they solve. Lexicons yield a massive number of false positives (FPs), inundating system operators with high numbers of erroneous flagged messages, making them virtually valueless. At Shield, we know that the world of detection doesn’t stay still. It’s not enough to simply set up lexicon-based models and hope that they will catch any potentially violating behavior that’s thrown at them. With that in mind, we continually add to, modify, and otherwise improve the detection models we used to provide updated coverage regarding the latest risk areas, along with new products, areas of business, mandated lines, and comments from regulators. Have the right tools in place Have the right tools in place
  • 7. This improves the relevance of alerts, cutting down FPs, while also detecting infringements that regular lexicon searches or AI-only systems will miss. The technology we have developed is able to detect any hints in conversations between traders — or any other personnel requiring oversight — to identify when a potential breach is taking place. We are even capable of building models able to analyze complex interactions when two people are speaking in two territories with different regulations. This is a major problem and challenge in global operations. By knowing the employee department, job, management line, and other relevant information, Shield constructs specialized models to surveil specifically the eComm interactions between different groups of employees like traders and marketers within its global wealth and global banking and global banking divisions. We combine new age lexicon technologies, along with the latest AI innovations, to provide the best quality surveillance system of eComms.
  • 8. Regulations separating the two sides of financial institutions are only going to get more stringent as time goes on. Fines are being handed out with increasing regularity — and merely paying lip service to detection through the installation of outdated detection tools isn’t enough. Firms must ensure that not only do they have a strong informational firewall in place but that they also have the detection tools present in case someone on either side finds a way over it.
  • 9. Contact Us Phone Number 97235685587 Email Address info@shieldfc.com Website https://www.shieldfc.com/