FCA Market Watch 66 - Market conduct and transaction reporting issues

On January 11, the FCA published its 66th Market Watch Newsletter, looking at market conduct and transaction reporting issues.

The newsletter highlights the need for firms to record telephone conversations and electronic communications when alternative working arrangements are in place, such as remote or home working.

In the newsletter, the FCA emphasises the key risks of reduced monitoring, the recording obligations authorised firms are subject to, and what this means for firms in terms of policies and training.

  • Risk of reduced monitoring

    Increased homeworking means misconduct may be heightened or increased. FCA expects firms to continue to comply with the recording obligations in their Senior Management Arrangements, Systems and Controls sourcebook (SYSC 10A). Firms need to ensure that all the activities are recorded and auditable.

  • Recording obligations 
    Firms need to record all the conversations and communications made with, sent from, or received on, equipment provided or permitted to be used for business purposes. These recording obligations may include internal conversations concerning in-scope activities.

  • What this means for firms
    Businesses need to be able to demonstrate to the FCA that their policies, procedures and oversight meet the recording rules. If new technologies or amended policies are introduced, FCA expect firms to provide enhanced or refreshed training to staff covering any conduct risks.


"Without effective recording and monitoring controls, there is a real risk of loss of monitoring and surveillance capability, and the absence of protection through loss of evidence to resolve disputes between a firm and its clients over transaction terms."

FCA Market Watch Newsletter, No 66, January 2021

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The 65th market watch newsletter looked at three areas that require attention in the fight against market abuse.

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FCA's 64th Market Watch Newsletter looks at transaction reporting issues as firms prepare for the end of the Brexit transition period.


SteelEye is a RegTech and data analytics firm that was established to reduce the complexity and cost of financial compliance and enable firms globally to manage their regulatory obligations through a single platform.

SteelEye’s ability to bring together, cleanse, index and analyse structured and unstructured data across all asset classes and communication types enables clients to effortlessly meet their regulatory needs, because when all this data is in one place, compliance becomes both easy and cost-effective. And with everything under one lens, firms also gain fresh insight into their business, helping them improve their efficiency and profitability.

To date, SteelEye has launched solutions for record keeping, trade reconstruction, transaction reporting, trade and communications surveillance, best execution reporting, transaction cost analysis and advanced analytics for regulations including MiFID II, EMIR, Dodd-Frank, SMCR and MAR. 



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