See this interesting article in LeapRate on the current and future approaches that the FCA are taking to trade surveillance. With the advent of REMIT and also MAD II/MAR we will soon see this type of activity being carried out in the energy trading industry as well.
The topic of whether one should run an internal surveillance system surfaced again at ETOT yesterday. So far only a few energy trading companies have one installed. And if you are not a “PPAT” (Person professionally arranging transactions) REMIT is unclear as to whether this is required.
However that does not mean that installing a surveillance system is a bad idea. The reputational risk that would be caused by breaches is large, and the last way a CEO would want to find out about abuse in the company is via a visit from the regulator, or even by reading it in the papers.
Therefore we can expect a far greater focus on surveillance over the coming years, especially as REMIT breaches (Articles 3 and 5) start to incur criminal sanctions in more countries.