A complete market abuse surveillance toolkit calibrated for Dutch investment firms. From detection logic for spoofing and layering to STOR procedures and insider list management — everything you need to meet your MAR obligations in practice, not just on paper.
AFM has intensified its focus on market abuse surveillance. This framework gives your compliance team the tools to detect, assess, and report suspicious activity — with confidence that your surveillance arrangements meet supervisory expectations.
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The Market Abuse Regulation requires every investment firm to have effective surveillance arrangements proportionate to the scale and nature of their activities. In practice, this means detection logic, escalation procedures, reporting templates, and insider management — all working together as a coherent framework.
Most firms either over-invest in expensive surveillance software that generates thousands of false positives, or under-invest with minimal procedures that won't survive an AFM inspection. This framework provides the operationally practical middle ground: effective surveillance that your compliance team can actually run.
Complete Suspicious Transaction and Order Report procedure aligned with ESMA's guidelines. Includes assessment templates, AFM filing format, internal documentation requirements, and timeline tracking.
Excel-based insider list management system covering permanent and event-based insider lists. Includes automated date tracking, access logging, NDA templates, and the notification procedures required under MAR Article 18.
Methodology for calibrating surveillance alerts to your firm's trading profile. Covers threshold setting, false positive management, back-testing procedures, and the documentation required to justify your calibration decisions.
Detailed definitions and detection logic for key market abuse patterns: spoofing, layering, front-running, wash trading, marking the close, and pump-and-dump. Each pattern includes practical indicators and assessment criteria.
Complete personal dealing policy template covering pre-clearance procedures, restricted lists, holding periods, and monitoring arrangements. Aligned with MAR and MiFID II requirements for employee trading.
Templates for periodic surveillance reporting to your board and senior management. Covers alert volumes, STOR statistics, insider list activity, and the compliance officer's assessment of surveillance effectiveness.
This framework is designed for investment firms that trade in financial instruments or provide services that involve order reception, execution, or portfolio management. It's calibrated for the Dutch market and AFM's specific enforcement priorities, making it particularly valuable for firms that want to ensure their surveillance arrangements are proportionate yet robust.
Not necessarily. For smaller firms with limited trading activity, the pattern definitions and manual review procedures in this framework may be sufficient. For firms with higher trading volumes, the framework serves as the procedural layer that sits on top of your surveillance software.
The pattern definitions and detection logic cover cross-market abuse scenarios. However, the data integration challenge of cross-market surveillance depends on your specific platform and data access. We address the procedural requirements and can advise on technical implementation separately.
Yes. Our MAR Surveillance workshop uses this framework as the basis for hands-on exercises. Purchasing both gives your team the materials plus the practical training to apply them effectively.