Risk Management

Automating governance, risk & compliance workflows

Risk management in the increasingly regulated world of capital markets is facing enormous change. Financial services firms have accepted the need to mitigate risk and are turning their attention towards strengthening their operating models and cultures to weave risk management controls into the fabric of their organisations.
GreySpark has the experience and expertise to establish and deliver new operating models that deliver confidence across entire businesses, regardless of the regulatory jurisdiction. Combining our strong procedural foundation, proven governance framework and Risk Management Development Kit, we provide clients with a scalable ability to manage risk and the implementation of controls under continuous supervision.

Our Value

Banks have been very successful in their responses to regulatory mandates establishing adequate levels of controls. However, approaches to risk and controls management remain inconsistent. Maturing this area will be of great benefit to the reputation and standing of banks.

GreySpark leverages expertise across electronic trading, regulatory change and trade surveillance to deliver strategic solutions tailored to meet your business requirements. We implement a vertically-integrated approach to risk management processes and controls and embed it into the fabric of the organisation, thereby delivering new cultural awareness across the entire bank.

We recognise that each problem is unique and that it is not possible or healthy to apply a one-size-fits-all technological solution. The GreySpark mission is to best utilise our expertise and cross-disciplinary teams to thoroughly understand our client needs, provide industry-leading, actionable advice and deliver innovative, bespoke solutions.

Interested in GreySpark's Risk Management Services?

We implement a vertically-integrated approach to risk management processes and controls and embed it into the fabric of the organisation, thereby delivering new cultural awareness across the entire bank.

Risk Management Service Offering

Electronic Trading Compliance and Risk Management

GreySpark’s Electronic Trading Risk Management services are specifically calibrated to help large financial institutions tackle the increasingly regulated world of capital markets. The service portfolio provides a proven governance foundation that scales across the electronic trading business for continuous supervision.

Health Check

  • GreySpark’s Health Check advisory and implementation service quickly determines gaps and weaknesses.


  • Governance framework provides assurances that the polices, procedures and controls are fully adopted to secure against regulatory risk.


  • Delivering sophisticated solutions with workflow management, risk assessment and real-time dashboards.
  • Providing metrics, reporting, controls and communications for build and run activities


  • Development of a ‘digital’ framework provides the foundation for a sustainable approach to compliance.

MiFID II RTS 6 Self-Assessment Practices

  • GreySpark Partners uses a risk management process to review, evaluate and validate a client’s algorithmic trading systems, governance, stress-testing, business continuity and compliance with Article 9 of MiFID II’s RTS 6 criteria.


MiFID II Health Check

The Regulators are coming…


It is clear that in the second half of 2018 the regulators and regional authorities, such as the FCA, will start to focus on firms’ compliance with MiFID II.

Regulators will inspect market participants to ensure compliance with the regulation.

GreySpark’s expectation is that institutions will see many of their non-compliant procedures exposed.

At the very least firms will need to be able to evidence activity working towards compliance.


Initial feedback to GreySpark indicates that the focus of the regulators will be on compliance within these key areas:

  • Algorithmic Trading
  • Best Execution
  • Electronic Trading
  • Pre-Trade Risk Control
  • Research Unbundling
  • Transaction Reporting
  • Transparency Reporting

Governance Framework

Managing your risks…


Simply altering existing policies and producing new documents, mapped to the regulatory requirements, is not enough. Regulators are looking for sustainability and enforcement throughout the organisation.

Documentation must not only meet all regulatory requirements, but also be developed in line with industry best practices, be consumable by an external regulator and be consistently deployed and implemented across the business.

A lack of top-to-bottom coordination and unclear oversight will lead to increased scrutiny from the regulator.


Establishing a governance framework and structured independent functions, providing oversight, allows for the identification of risk.

Adequate identification of risk allows for necessary adjustment to:

  • 1st Line of Defence documentation
  • 2nd Line of Defence documentation
  • Regulatory Controls

Monitoring Adherence and Risk Management

Enabling iterative changes…


The dynamic regulatory landscape requires an operational shift in the industry’s approach to new legislation.

A ‘digital’ framework for regulatory management introduces the ability to improve the adaptability of an organisation.

By implementing the aforementioned framework, regulatory change can be realised in an iterative manner that best utilises the existing resources.


Establishing a ‘digital’ framework through GreySpark’s ability to:

  • Establish organisational requirements
  • Leverage industry leading market intelligence across vendor landscape
  • Implement technological solutions
  • Provide SME oversight

Adaptability to a Changing Regulatory Landscape

Engaging with future iterations…


There is a consistent trend of global regulatory upheaval, with advantages to be gained by firms that can best react to this dynamic situation.


Initial feedback to GreySpark indicates the current key regulatory challenges that firms are working towards are:

  • Brexit
  • Capital Requirement Directive IV (CRD IV)
  • Fundamental Review of the Trading Book (FRTB)
  • MiFID II implementation
  • Model Risk Management (SR 11-7 & TRIM)
  • Money Markets Fund Regulation (MMFR)
  • Securities Financing Transactions Regulation (SFTR)
  • Senior Managers & Certification Regime (SMCR)

MiFID II RTS 6 Self-Assessment Practices


Financial services firms are now being monitored up by EU regulators to review their annual self-assessment of algorithms against the MiFID II RTS 6 requirements.

Given the increased level of regulatory attention, it is important that those firms begin to consider the best approach for the self-assessment and effective operation of algorithmic trading environments.


Establishing a comprehensive and well-documented self-assessment report, measured against industry best practices and address any gaps identified.

GreySpark Can:

  • Produce a Self-assessment Report;
  • Benchmark existing Self-assessment Reports against Industry Best Practices; and
  • Support Remedial Activities and Prioritise a Programme of Work to Address Identified Gaps as needed.


  • Best Practices in Pre-Trade Risk Controls 2016

NewsRisk Management
12 Apr, 2018

Autonomous Drive to E-Trading Governance

The growing use of algorithms to automate trading activities is garnering increasing regulatory attention, which highlights the need for dedicated risk management processes and systems.
BlogRisk ManagementSellside Trends
25 May, 2017

Pre-trade Risk Controls

This article was originally published by Best Execution magazine As automated trading emerged, the term ‘Flash Crash’ entered the industry vocabulary. Now, when creating algorithms or providing High Frequency Trading…
Press ReleasesRisk Management
12 Dec, 2016

Regulations are Driving Risk Management Systems to Become More Sophisticated and Integrated into Business, IT and Operational Processes

A new report from GreySpark Partners, a leading global capital markets consulting firm, assesses seven technology vendor solutions that address market risk, credit risk, liquidity risk and counterparty risk in…

Case Studies

30 Aug, 2017 in Case Studies, Risk Management

Audit and Compliance – Electronic Markets

In response to a historical incident that resulted in a financial loss for the bank, Electronic Markets has decided to take a pro-active approach to a number of other (historical)…
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30 Aug, 2017 in Case Studies, Regulatory Compliance, Risk Management

Algorithm Risk Control Management and Reporting – Integration with Model Risk Management Process

For regulatory purposes, the client’s electronic FX and Fixed Income businesses have identified a need to document and evidence their catalogue of eTrading algorithms, detailing and evidencing a series of…
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30 Aug, 2017 in Case Studies, Risk Management

Algorithm Risk Management (ARM) Governance Policies, Standards, and ATP Validation Infrastructure

Under the obligation set out by the OCC and CFTC the client required assistance in developing the foundation elements for a Algorithm Risk Management (ARM) framework.
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30 Aug, 2017 in Case Studies, Risk Management

Electronic Trading Risk Control Analysis and Oversight Governance Council Framework

Under the obligation set out by the OCC and CFTC the client required assistance for full self-disclosure in the form of documented due-diligence of their Automated Trading Programs (ATP) across…
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30 Aug, 2017 in Case Studies, Risk Management

Pre-Trade Risk Controls Review

In response to the Knight Capital loss and the HKSFC consultation on electronic trading, this leading Australasian investment bank approached GreySpark to assist in an independent review of the current…
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12 Mar, 2015 in Case Studies, Project Delivery, Risk Management

Electronic Execution Systems – Risk Controls Assessment

Following a preliminary Pre-Trade Risk review done by GreySpark, this leading Australasian investment bank required GreySpark to perform the actual assessment for its entirety of Electronic Execution Systems (EES).
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