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The challenge

The Sustainable Markets Initiative (SMI) aims to create a coordinated worldwide effort by the private sector to accelerate the achievement of global climate, biodiversity and Sustainable Development Goal targets.

As a supporter of the SMI, the client needs to be able to assess whether stock exchanges in certain markets are eligible for investing in, and meet the requirements of the Collective Investment Schemes Regime (CISR) (set out in the UK Financial Conduct Authority (FCA) Handbook).

The client is particularly concerned with the following CISR requirements under rule COLL 5.2 (General investment powers and limits for UCITS schemes):

  • COLL 5.2.8R – Transferrable securities and money-market instruments generally to be admitted to or dealt in on an eligible market
  • COLL 5.2.9R – Eligible markets regime: purpose
  • COLL 5.2.10R – Eligible markets: requirements

The CISR is not new, but a lack of readily available and comprehensive data on global markets and their exchanges can still make compliance a struggle.

How we helped

Because there is no limit to the number of countries that can be accessed through our database, the Market Eligibility form in Orbit Diligence allows the client to quickly identify the suitability of any given market against the requirements of the CISR and the SMI.

The form has five sections. The top three apply to UK-based exchanges and can be answered by the client directly, but section four has specific questions aimed at assessing if a non-UK based exchange is regulated, liquid and accessible for foreign investors.

We have mapped the data fields in SMI for the market where the relevant stock exchange is based, and for which responses to those questions may be relevant.

The fields include both specific information about the exchange and general information about the market the exchange serves. The client must decide whether the market meets its requirements, using our data to support its decision.

The data is downloaded in a Lists tab, and used as the basis for formulas in the Report tab. This allows the client to validate information about all the exchanges in a market. 

We designed the second form, Operations Suitability, to respond to a set of questions formulated by the client to ascertain market eligibility. This form will be used if the Market Eligibility form confirms that the exchange might be eligible.

The report aggregates in tabs all the fields from SMI and CSD reports that could help the client to answer its question – in other words, to interrogate the database.

The client finds both forms useful, and save the firm time when it’s looking for specific information in the SMI reports.

Want to identify suitable markets for new investments with ease?

Director of a Major Middle Eastern CSD

“The evaluation is very beneficial not only for our IT Security team but for the company as a whole. As CSDs we have to be as prepared as we can be against cyber risks, so Thomas Murray’s new initiative will be a golden key for that.”

Director of Cyber Security, Latin American financial institution

“The tool is good for us to identify cybersecurity risks to which our domain and its sources are exposed, as well as how to mitigate them.”

Head of Network Management, a European Bank

“Thomas Murray provided information we do not get by any other means today. It’s very useful. The tool is impressive and a nice answer to a problem in the banking industry: how do you manage a large network of service providers, distributors, partners and other third parties without costs creeping up? Cyber is going to be on the agenda for years to come and this tool is going to help us to keep ahead of our third-party risk management requirements.”

Cyber Specialist, third-party risk management at a US bank

“Responses to cyber questionnaires can be very PR-focused, and it’s difficult to get transparency. Security ratings cut through poor response rates to provide a health check based on objective, verifiable public data. We have integrated Thomas Murray’s cyber risk ratings and threat intelligence into our monitoring of agent banks and CSDs globally, and are looking to add additional groups from across the bank.”

IT Security Officer at a Central European bank

“The tool is well-designed and very user-friendly. Monitoring service providers and other third parties’ cyber risk is going to become a regulatory imperative soon; right now it is best practice and something banks should be looking at. Thomas Murray’s platform is great for monitoring our third parties, particularly those who are not very transparent in their DDQ responses. We really like the ability to benchmark our bank and our service providers against like-for-like peers and competitors, this is really important.”

CISO responsible for TPRM at a Global Bank

“The established US threat intelligence providers are expensive and only part of the puzzle. Thomas Murray’s new platform is a very, very good tool for managing our third parties – it is fully automated and isn’t ‘noisy’, which can become a serious relationship issue with some providers. My team really likes the look and feel of the platform as well as the clarity of thought that has gone into making this tool.”

IT Security Specialist of a Swiss financial institution

“Thomas Murray Cyber Risk is a great complement to the tools we use today. It provides much more comprehensive information around the vulnerabilities in our IT infrastructure – and particularly has a lot more details about breached employee emails and passwords than other providers. This is extremely helpful as it allows us to contract those employees with specific, actionable intelligence, and so that we can improve the email behaviour of all staff.”

CISO of an African financial institution

“The tool is very interesting. It gives us the capability to be proactive, rather than reactive, about building the security of our core infrastructure. We are a regulated company and subject to military surveillance by our government; Thomas Murray’s tool used ethical and indirect methods to discover every week the vulnerabilities that we would normally identify during our annual penetration testing.”

Head of IT Security of a Latin American stock exchange

“The Cyber Risk platform is more complete than our existing vulnerability scanning, and we will use it to either replace or complement it. The benchmarking in particular is extremely useful.”

Director of a large Turkish financial institution

“We have been able to make major improvements to our critical applications since using the tool, increasing our score and identifying further action points to stabilise our overall rating in future. Thomas Murray has enabled us to improve our internal processes as well, by pulling together all the necessary threat intelligence feeds so that my team can focus on implementing the findings, instead of gathering the data.”

CISO, Global Custody Bank

“Thomas Murray Cyber Risk’s approach is sophisticated. Its machine learning algorithm identifies our third parties’ public IT infrastructures with huge accuracy and requires no manual intervention. We feel we can place reliance on the ratings to build a robust third-party risk management framework. The solution was new to us, but the scope and accuracy of the data is better than anything I have seen in the market.”

Head of Network Management, Global Custody Bank

“In the past, we only had occasional contact with our IT Security team, who helped to validate the responses to some DDQs [due diligence questionnaires]. Recent regulations and geopolitical events demonstrated to our bank the need to monitor the cyber risk of our post-trade counterparties around the world. Thomas Murray has been instrumental in developing such a programme for us, and in bringing Network Management and IT Security together."

Orbit Diligence

Orbit Diligence

Automate your DDQ and RFI processes for a wide range of use cases, accessing a library of off-the-shelf questionnaires and risk frameworks.

Learn more

Contact an expert

Derek Duggan

Derek Duggan

Managing Director | Banks

Sarah Nelson

Sarah Nelson

Senior SaaS Sales Executive | SaaS sales