Trading Platform Remediation & Regulatory Control

An index trading platform had grown on the trading desk over several years without adherence to core architectural principles, progressively outsourced across multiple vendors with significant loss of institutional IP. The platform became fragile and unreliable, and a month of market volatility exposed a data quality issue resulting in a significant trading loss. Existing controls fell short of MiFID II requirements, and the combination of financial loss and regulatory risk made the status quo untenable, putting the Global Equities COO under pressure to resolve the situation quickly.

We immediately locked down change on the existing platform to halt further deterioration and stabilise the baseline, while communicating a realistic roadmap and frequent updates to reduce stakeholder pressure. We defined a two-phase strategy, stabilise the platform first, then unwind and rebuild it sustainably, and shifted ownership and controls away from the front office and disparate vendors into a properly governed technology function, navigating tension between the trading desk’s demand for speed and compliance’s demand for control. We built a Target Operating Model in partnership with the platform’s future technology owner, defining a consolidated vendor approach.

The system was brought under control within one month, with minimum expected controls in place and manual workarounds phased out over 12 months. We achieved a control environment aligned with MiFID II obligations, transferred platform ownership from the front office to a dedicated technology function, and replaced a fragmented multi-vendor landscape with a single, controlled vendor approach. The platform was ultimately rebuilt within IT as part of the approved target architecture, and the episode prompted proactive reviews of other shadow IT systems across the client.