Foreign Exchange Solution Sheet
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1 Foreign Exchange Solution Sheet Proactively Detecting Market Manipulation PHONE (615) WEB digitalreasoning.com ADDRESS 730 Cool Springs Blvd Suite 110 Franklin, Tennessee Copyright All Rights Reserved. Digital Reasoning and Synthesys are registered trademarks of Digital Reasoning Systems, Inc.
2 Foreign Exchange Solution Sheet 2 Table of Contents Executive Summary 3 Collusion, Misconduct & Manipulation 3 Colluding and Communicating 4 Level Playing Field? 4 The Digital Reasoning Approach 4 Published by Digital Reasoning Systems, Inc., 730 Cool Springs Blvd, Suite 110, Franklin, TN Digital Reasoning and Synthesys are registered trademarks of Digital Reasoning Systems, Inc. Designations used by companies to distinguish their products are often claimed as trademarks. In all instances where Digital Reasoning Systems, Inc., is aware of a claim, the product names appear in initial capital or ALL CAPITAL LETTERS. Readers, however, should contact the appropriate companies for more complete information regarding trademarks and registration. Published in the United States of America. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning or otherwise, except as permitted under Sections 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to Digital Reasoning Systems, Inc., or via distribution with a licensed copy of the Synthesys machine learning platform from Digital Reasoning Systems, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. While every precaution has been taken in its preparation, the publisher assumes no responsibility for errors or omissions, or for damages resulting from the use of the information herein.
3 Foreign Exchange Solution Sheet 3 Executive Summary The foreign exchange (FX) market is a global market for the trading of currencies. In terms of volume of trading, it is by far the largest market in the world with an estimated daily turnover of $5.35 trillion. The main participants in this market are the larger international banks who make up the interbank market and their clients, large institutional customers. Currency exchange between these large market participants is often conducted on proprietary platforms that do not always provide market transparency into the orders that are filled, their volume or value. Unlike the equity markets, which provide relative transparency into buys and sells on the large platforms, such as the Nasdaq, the FX market especially at the top level is relatively non-transparent, which makes understanding the true value of any currency difficult. Because of this, and the need for a trusted source of currency values across all major currency pairs, the FX industry agreed to establish a set of daily benchmark rates. The most predominantly used industry benchmark is the 16:00 GMT WM/Reuters Fix, which is based on orders being executed on the Reuters platform at that time. Currency rates produced by the FX benchmark are subsequently used by risk management systems to help value portfolios, treasury management systems to help determine cash flow by large corporate customers, and generally by the market to help establish the cost of goods and services being traded globally. Therefore, the credibility of the daily FX benchmark is critical to the health and wellbeing of the global financial system and the businesses that rely on it. Collusion, Misconduct & Manipulation Although the vast majority of participants within the FX market conduct themselves in a professional and upstanding manner, many individuals within the FX market started questioning the reliability and credibility of the daily FX benchmark due to pricing and volume anomalies that were being seen around the 16:00 GMT fix. This subsequently led to a series of investigations conducted by the Commodity Futures Trading Commission (CFTC) within the US and the Financial Conduct Authority (FCA) within the UK. Unfortunately, it was discovered that a group of FX trading professionals within many of the largest FX banks, both in the US and UK, were colluding in an effort to fix the daily fix. By placing orders ahead of the fix and agreeing between the banks as to who s selling and buying, and at what volume, these FX professionals were able to move the FX market in a predetermined direction so that the benchmark on a given currency would settle at a favored rate. In many cases a trader could move the market with a couple of well-placed orders. When working together, traders were able to move the market and benchmark with greater precision and predictability therefore collectively profiting.
4 Foreign Exchange Solution Sheet 4 Colluding and Communicating These traders, known amongst themselves as the cartel, became proficient at fixing the daily benchmark. By using electronic communication tools at their disposal, such as and chat rooms, the cartel participants were able to communicate and collude in real time, place orders together, watch the market move in their favor and congratulate themselves as they succeeded. As the cartel considered bringing in new members in order to have greater flexibility on how they influenced the behavior of the market, they communicated amongst themselves as to whom they could trust and why they should be included. All of these communications were conducted openly without the banks knowledge, and subsequently discovered and made public by the CFTC causing immeasurable damage to the FX market, the financial services industry, and each of the financial institutions involved. Level Playing Field Financial institutions have invested heavily in surveillance and monitoring technologies, with a goal of detecting employees and customers who may be putting their bank at risk. Often, however, these technologies do not have the capability to analyze and understand the information being processed. This is especially true when it comes to electronic communications. A contributing factor in the FX scandal is the unique makeup of language and terms that are widely used within the FX industry, making it difficult for traditional keyword based and pattern matching technologies to accurately reveal risky communications. Looking for terms like yard, cable or fix which are all terms legitimately used over the course of a typical FX trading day would yield numerous false positives, making it difficult to determine the signal from all the noise. Communications are often abbreviated, or certain words are avoided entirely in order to avoid detection, making current surveillance technologies inadequate. Unfortunately, most current electronic communications surveillance systems fall short in detecting risks after the fact, and very few proactively detect risky communications as they are taking place. This ends up favoring the financial criminal and not the financial institution this is certainly not a level playing field. The Digital Reasoning Approach Our machine learning-based analytics platform, Synthesys incorporates a more human-like intelligence approach that uses a graph-based knowledge model to enable predictions based on a high-fidelity representation of context. And, like the human mind, our technology learns, adapts and gets smarter over time. Our software looks at communication in different ways, interprets different meanings of signals, and then it uses reasoning and experience to clear away the ambiguity and pinpoint the truth revealing previously unknown relationships, risks and threats. Our approach provides results by analyzing every communication, narrative and description. Synthesys reads through all your data and highlights the important people, places, organizations, events and facts being discussed. By semantically analyzing a financial institution s electronic communications, matched with our expertise in understanding how FX professionals communicate, Synthesys reveals: Risky communications with external counterparties Obfuscated dealing language relevant to currencies and the fix
5 Foreign Exchange Solution Sheet 5 Unethical activity and breaches of confidentiality Evidence of market manipulation by dealing professionals Synthesys can be 10x-15x more accurate than other solutions that depend on keywords, lexicons, regular expressions or pattern-matching to analyze communications. Built on a scalable platform that can grow with business usage, Synthesys can provide considerable cost savings and operational leverage while enhancing surveillance precision and detection. For instance, the chat exchange below would not trigger any alerts by most lexicon/keyword and/ or regular expression/pattern matching solutions: Bank A Trader: 03:34:01 pm what s on the menu this afternoon, gents? Bank B Trader: 03:34:20 pm kiwi Bank C Trader: 03:35:19 pm kwii? at this timez? Bank B Trader: 03:38:54 pm i luv it. i want 40 usd Bank A Trader: 03:40:22 pm im in Bank C Trader: 03:48:41 pm having some now Bank B Trader: 03:49:03 pm lets go its almost time Bank A Trader: 04:00:37 pm brilliant Bank C Trader: 04:01:40 pm that was delish Where other technologies fail, Synthesys succeeds by identifying language related to currency, time, praise, & breach of confidentiality. These four features combined would trigger a key indicator for Manipulation. To further illustrate this, the table below provides a comparison of the different technical approaches used by vendors when analyzing electronic communications: Lexicon/Keyword based Solutions Pattern-matching / Regular expression based Solutions Digital Reasoning - Synthesys Approach Outcome Bottom Line Simple searching and filtering, targeted search More complex rules, makes search less sensitive to misspellings Machine-learning based, contextual understanding, scalable analytics High false positives, cannot handle misspellings, no understanding of context, requires huge dictionary High false negatives, no word sense or context, requires large list of complex patterns/ expressions, large computational load Significantly reduced false positives. Damaging risks and relationships identified earlier in the surveillance process May offer little operational efficiency and cost savings True risks are often missed Better. But operational efficiency comes at the cost of precision Best. Accuracy with operational efficiency True risks revealed For more information on Synthesys and its FX market manipulation surveillance capabilities, visit the Digital Reasoning FX site at: fx.digitalreasoning.com
6 Foreign Exchange Solution Sheet 6 FOR MORE INFORMATION, VISIT OUR WEBSITE AT: OR CONTACT US AT: Digital Reasoning Systems 730 Cool Springs Blvd Suite 110 Franklin, TN p f info@digitalreasoning.com Published by Digital Reasoning Systems, Inc., 730 Cool Springs Blvd, Suite 110, Franklin, TN Digital Reasoning and Synthesys are registered trademarks of Digital Reasoning Systems, Inc. Designations used by companies to distinguish their products are often claimed as trademarks. In all instances where Digital Reasoning Systems, Inc., is aware of a claim, the product names appear in initial capital or ALL CAPITAL LETTERS. Readers, however, should contact the appropriate companies for more complete information regarding trademarks and registration. Published in the United States of America. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning or otherwise, except as permitted under Sections 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to Digital Reasoning Systems, Inc., or via distribution with a licensed copy of the Synthesys machine learning platform from Digital Reasoning Systems, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. While every precaution has been taken in its preparation, the publisher assumes no responsibility for errors or omissions, or for damages resulting from the use of the information herein. PHONE (615) info@digitalreasoning.com WEB digitalreasoning.com ADDRESS 730 Cool Springs Blvd Suite 110 Franklin, Tennessee Copyright All Rights Reserved. Digital Reasoning and Synthesys are registered trademarks of Digital Reasoning Systems, Inc.
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