Essays··10 min read
What Can You Actually Test
The FCA's August 2025 review of algorithmic trading controls at ten principal firms found significant variation in compliance sophistication — but the structural problem is older than the review. Attestation requires a compliance officer to certify what an algorithm does when she cannot read the code, testing covers yesterday's scenarios, and surveillance measures what someone thought to calibrate. The FCA has named the gap; the attestation merely documents that the firm knows it exists.
algorithmic-tradingfinancial-regulationcompliancemarket-surveillance
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