Interactive paper 02

AI for trade surveillance operations

A working map for leaders who need to improve surveillance without moving accountability away from the people who hold it.

This is a public discussion aid. It is not legal, regulatory, investment, or technology advice, and it does not assess your controls.

Operating map

Six places to inspect before changing the technology

The map separates preparation from accountability. It is designed to structure an executive conversation, not to score a firm.

Coverage and lineage

Can the programme account for every in-scope order, trade, venue, account, and data hand-off?

AI can prepare: Prepare a coverage inventory and flag gaps for review.
A person decides: Set scope, materiality, and the evidence standard.

Detection scenarios and calibration

Which scenarios still find meaningful risk, and where does alert volume hide it?

AI can prepare: Compare alert patterns and prepare calibration questions.
A person decides: Approve thresholds, scenario changes, and model release.

Alert triage and investigator rationale

Can an investigator explain why an alert was closed, escalated, or reported?

AI can prepare: Organise facts and draft a traceable case summary.
A person decides: Reach the investigative conclusion and make every escalation decision.

Quality assurance and testing

Does testing show that the controls work across products, regions, and changing market conditions?

AI can prepare: Prepare testing packs and identify recurring quality findings.
A person decides: Set the test plan, challenge results, and accept remediation.

Governance, model change, and evidence

Can senior owners trace a control or model change from approval to production evidence?

AI can prepare: Assemble change records and compare required documentation.
A person decides: Own accountability, separation of duties, and change approval.

Examination, remediation, and continuous improvement

Can the firm show what it found, what it changed, and how it tested the result?

AI can prepare: Prepare an evidence index and a remediation-workflow outline.
A person decides: Set the regulatory response and confirm remediation is complete.

Regulatory signals

Questions grounded in public supervisory material

Sources are linked so a reader can test the evidence directly. Checked 31 July 2026.

FINRA · 2025-12-09
2026 Annual Regulatory Oversight Report
The report includes a new GenAI section and identifies supervision, authority, auditability, and data handling as concerns for AI agents.
Financial Conduct Authority · 2025-12-09
Market Abuse Surveillance TechSprint
The TechSprint examined alert accuracy, complex market abuse, and anomaly detection, including approaches intended to reduce false positives.
ESMA · 2026-02-26
Supervisory briefing on algorithmic trading in the EU
The briefing addresses governance, testing, outsourcing, and AI considerations for algorithmic trading systems.
CIRO · 2026-03-24
Guidance on Certain Manipulative and Deceptive Trading Practices
The guidance addresses policies, testing, automated controls, real-time alerts, and post-trade review for automated order systems.

Work with CaL

Prepare a surveillance executive session

Twenty-five minutes to frame one operating question. AI can prepare a brief only after a person approves the scope. A qualified person leads the discussion.

Ask CaL

Bring one control, migration, or alert-quality question. The brief stays in this browser and helps you decide whether a human conversation is useful.

Submit to CaL

Frame a programme, migration, control model, or examination question for a bounded adversarial review. Do not attach or paste confidential material.

Six places to inspect before changing the technology

The map separates preparation from accountability. It is designed to structure an executive conversation, not to score a firm.

Coverage and lineage

Can the programme account for every in-scope order, trade, venue, account, and data hand-off?

AI can prepare: Prepare a coverage inventory and flag gaps for review.
A person decides: Set scope, materiality, and the evidence standard.

Detection scenarios and calibration

Which scenarios still find meaningful risk, and where does alert volume hide it?

AI can prepare: Compare alert patterns and prepare calibration questions.
A person decides: Approve thresholds, scenario changes, and model release.

Alert triage and investigator rationale

Can an investigator explain why an alert was closed, escalated, or reported?

AI can prepare: Organise facts and draft a traceable case summary.
A person decides: Reach the investigative conclusion and make every escalation decision.

Quality assurance and testing

Does testing show that the controls work across products, regions, and changing market conditions?

AI can prepare: Prepare testing packs and identify recurring quality findings.
A person decides: Set the test plan, challenge results, and accept remediation.

Governance, model change, and evidence

Can senior owners trace a control or model change from approval to production evidence?

AI can prepare: Assemble change records and compare required documentation.
A person decides: Own accountability, separation of duties, and change approval.

Examination, remediation, and continuous improvement

Can the firm show what it found, what it changed, and how it tested the result?

AI can prepare: Prepare an evidence index and a remediation-workflow outline.
A person decides: Set the regulatory response and confirm remediation is complete.

Prepare a surveillance executive session

Twenty-five minutes to frame one operating question. AI can prepare a brief only after a person approves the scope. A qualified person leads the discussion.

Ask CaL

Bring one control, migration, or alert-quality question. The brief stays in this browser and helps you decide whether a human conversation is useful.

Submit to CaL

Frame a programme, migration, control model, or examination question for a bounded adversarial review. Do not attach or paste confidential material.

AI for trade surveillance operations

Six places to inspect before changing the technology

Coverage and lineage

Detection scenarios and calibration

Alert triage and investigator rationale

Quality assurance and testing

Governance, model change, and evidence

Examination, remediation, and continuous improvement

Questions grounded in public supervisory material

Prepare a surveillance executive session

Ask CaL

Submit to CaL

Prepare a session brief

AI for trade surveillance operations

Six places to inspect before changing the technology

Coverage and lineage

Detection scenarios and calibration

Alert triage and investigator rationale

Quality assurance and testing

Governance, model change, and evidence

Examination, remediation, and continuous improvement

Questions grounded in public supervisory material

Prepare a surveillance executive session

Ask CaL

Submit to CaL

Prepare a session brief