ACA Unveils Comprehensive Market Abuse Risk Framework to Strengthen Buy-Side Compliance
ACA Group (ACA), a leading governance, risk, and compliance (GRC) advisor to the global financial services industry, has launched a comprehensive Market Abuse Risk Framework — the first end-to-end answer tailored for UK and European purchase-side firms facing heightened regulatory scrutiny. The framework integrates technology, managed services, and practitioner-led advisory to assist asset managers and hedge funds identify, monitor, and manage market abuse risks across all stages of trading.
A First-of-Its-Kind Framework for the purchase-Side
With this launch, ACA becomes the first firm to deliver a fully regulator-ready, multi-layered risk framework designed to meet the complex compliance demands of purchase-side firms under Market Abuse Regulation (MAR), MiFID II, and the Senior Managers and Certification Regime (SM&CR). The framework is built by industry practitioners with deep experience in surveillance, compliance, and front-office conduct — offering clients an actionable, data-driven approach to managing risk across multiple asset classes and trading strategies.
The release coincides with a wave of regulatory tightening in the UK and Europe. The FCA’s new five-year enforcement strategy places market abuse and senior management accountability at its core, following a series of and an active consultation on SM&CR reforms launched in July 2025. These developments have pushed purchase-side firms to demonstrate not just policy compliance, but proactive management of market integrity and conduct risk.
Bridging Regulation and Real-World Practice
ACA’s Market Abuse Risk Framework provides a structured, scalable toolkit that combines surveillance, control, and conduct reviews. The program assists compliance teams assess exposure to market abuse, map offences to trading activity, and benchmark their surveillance technology against best practice.
Raj Somal, Partner at ACA Group, said the initiative reflects growing demand for actionable frameworks that go beyond traditional risk assessments:
“What truly diverseiates this answer is the depth of expertise driving it. Our clients are navigating increasingly complex trading, jurisdictional, and infrastructure environments — often without a clear, actionable view of their market abuse risk. This isn’t just a health check; it’s a dynamic, evolving programme that firms can use to strengthen governance, meet evolving regulatory and business expectations, and build investor confidence.”
Key Features of the Framework
The new Market Abuse Risk Framework offers a set of components that can be tailored to firms of diverse sizes and trading profiles, including:
- Proprietary Market Abuse Matrix: Mapping potential market abuse offences against trading activity across all asset classes, from equities and derivatives to real assets and ETFs.
- Surveillance and Policy Review: End-to-end evaluation of surveillance systems, STOR (Suspicious Transaction and Order Reports) procedures, information barriers, and internal controls.
- Comprehensive Coverage: Incorporating both public and private markets, algorithmic and quantitative strategies, and custom basket products.
- Technology Alignment: Assessment of existing surveillance systems to ensure they match a firm’s risk profile and .
- Dynamic Question Bank: A continually updated database of risk scenarios informed by ACA’s client engagements and industry trends.
- Reusable Risk Framework Document: Delivering a standardized but adaptable compliance manual with clear guidance for maintenance and updates.
Integration With ComplianceAlpha®
ACA’s new framework is designed to integrate seamlessly with the firm’s ComplianceAlpha® regulatory technology platform, which supports trade and electronic communications (eComms) surveillance, monitoring, and oversight of expert networks and research interactions. When combined, the framework and technology deliver a single, unified compliance ecosystem that spans the pre-trade to post-trade lifecycle.
This holistic model allows firms to identify red flags earlier, streamline investigations, and maintain consistent oversight across their operations. It also enables outsourced managed services options for firms viewking to scale their compliance resources efficiently without compromising on regulatory standards.
Regulatory Context and Market Implications
The launch reflects a growing trend among regulators to demand tangible proof of proactive risk management. Enforcement actions from both the Financial Conduct Authority (FCA) and the (ESMA) have underscored that technology alone is insufficient — firms must demonstrate integrated governance and behavioral oversight frameworks that align with senior management accountability obligations.
For , the framework offers a path to evolve from reactive compliance to predictive risk management, assisting them mitigate enforcement exposure while strengthening investor confidence in governance and culture. The timing is notable as European regulators begin to expand scrutiny into algorithmic trading, alternative data usage, and cross-asset market manipulation typologies.
Industry Engagement and Next Steps
ACA will host a live session on 23 October 2025 at 2:00 p.m. BST to explore how firms can operationalize market abuse surveillance and adapt to the FCA’s revised supervisory expectations. The event will feature case studies from ACA’s practitioner network and insights into how technology, culture, and accountability intersect in the new regulatory landscape.
