Monitor Remote Work
Businesses are increasingly asking their employees to selfquarantine, practice social distancing and stay home. But, what if you’re a financial trades broker or firm, how do you monitor transactions, behaviors and eComms outside of your office? This virus may be thwarting efforts to socialize and attend large scale entertainment attractions, but it’s certainly not going to curb efforts to leverage the crisis for the purpose of perpetrating market abuse crimes.
VOLATILE MARKETS ARE BUSY TIMES For many investors, volatile markets signal that it’s time to act. The world is currently hopeful that this pandemic will ease up once the summer starts. And, as is the case for every US election year, the instability of the markets in the months before the vote is typically replaced with a vigorous rally once a new President is selected. This could be a bumpy ride. For how long, nobody knows, but it’s going to put additional strain on global and local economies, as well as on the people. ARE YOU READY FOR WORK-FROM-HOME? Many businesses have not yet drafted policies that meet current applications of technology and eComms, let alone established strict protocols governing monitoring and surveillance in the event of a global crisis.
HOW TO DEVELOP A CONTINGENCY PLAN AS A FINANCIAL INSTITUTION As it is the case for nearly everything, you simply don’t know what you don’t know…until you know that you don’t know it. That’s a rather convoluted way of stating that, because you can’t be ready for everything, you need to conduct a scenario planning exercise then establish a contingency plan for as many scenarios as possible. But where do you begin? Audit everything. Conduct an inventory of every mobile phone, laptop and IoT device on your network. Who owns it and, if it’s an approved device, what software is on it? If it’s not approved, obviously immediately disable access. This will take considerable time. In parallel, begin generating a list of “acceptable” or approved software and applications for any IoT device connected to your firm’s secure network. Create a detailed roster beginning with a registration list of all employees, their physical home address, home phone, and mobile phone numbers plus their supervisor’s home address, home phone, and mobile phone numbers. All titles, registrations, and lists of approved business activities must be captured. If any employee has had a history of discipline problems or coronavirus compliance violations, consider restricting remote access for those employees. Enable an onsite and remote work inspection team. Ensure that they have the required authorizations and systems access to conduct their inspections. Enablement includes providing a clear definition of how and how often these inspections will be conducted.
These are challenging times. It’s unclear how long it will take for financial institutions to reign in all eComms, trades and other business functions for appropriate surveillance operations. However, a systematic approach to defining your firm’s business practices and the technologies used to enable those practices can help you navigate this ongoing market storm and prepare you for the future of work which is increasingly tilted to working-fromhome.
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