We have two products to date:

(1) the Covered Funds bot, a rules-based AI tool to ensure compliance with the Volcker Rule’s prohibition to invest in or sponsor so-called “covered funds”; and
(2) the MiFID II bot, a robotic process automation tool which, combined with a rules-based AI engine, provides automatic, immediate and consistent compliance with client protection obligations under MiFID II, such as:
a. Inducements, Research unbundling and Product governance,
b. Ensuring that products are offered only to clients within the right target market,
c. Providing pre-trade information and product disclosures to clients,
d. Evidencing exact date and time when client has read each notification,
e. Pre-assessing client’s requests to change classification,
f. Determining suitability and appropriateness, precluding the possibility of offering not suitable products a client, and generating and notifying suitability reports.
g. Additionally, it is fully auditable, PRIIPs and GDPR compliant...
We have two products to date:

(1) the Covered Funds bot, a rules-based AI tool to ensure compliance with the Volcker Rule’s prohibition to invest in or sponsor so-called “covered funds”; and
(2) the MiFID II bot, a robotic process automation tool which, combined with a rules-based AI engine, provides automatic, immediate and consistent compliance with client protection obligations under MiFID II, such as:
a. Inducements, Research unbundling and Product governance,
b. Ensuring that products are offered only to clients within the right target market,
c. Providing pre-trade information and product disclosures to clients,
d. Evidencing exact date and time when client has read each notification,
e. Pre-assessing client’s requests to change classification,
f. Determining suitability and appropriateness, precluding the possibility of offering not suitable products a client, and generating and notifying suitability reports.
g. Additionally, it is fully auditable, PRIIPs and GDPR compliant and multi-language.

The MiFID II bot is made out of five modules:
(i) the Products & Services catalogue,
(ii) the Client Catalogue,
(iii) the Compliance Dashboard,
(iv) the Suitability & Appropriateness Module, and
(v) the Client Portal.
These five modules interact with each other to deliver an end-to-end solution.

The Products & Services Catalogue is the backbone of the bot, where full product governance, inducements controls and research unbundling controls take place and are stored.

When the information in the Products & Services Catalogue is compared to the information of each client, the Client Catalogue determines whether Suitability or Appropriateness apply, or if the Execution-only exemption applies, and notifies to each client that information, together with all applicable disclosures (including those about permitted inducements and research unbundling), both by email and via the Client Portal. Every time client opens a notification, a timestamp is generated showing the relevant date for evidentiary purposes.

From the Client Portal, clients may request a change of classification, complete Suitability and Appropriateness questionnaires (which will be automatically assessed by the Suitability & Appropriateness module and displayed on the Compliance Dashboard for recordkeeping purposes), and even execute trades, at which point the entity’s trading portal takes over where applicable, or an RFQ is automatically generated and sent to the entity for execution.
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