In order to satisfy their Senior Management Systems & Control (‘SYSC’) obligations the client engaged IP Sentinel to provide a Business Continuity Plan and to implement Regulatory Archiving of Electronic Communication.
The client is a UK, Switzerland and EU based Broker and Investment Adviser that has an outsourced IT system provided by a “Private Cloud” provider.
IP Sentinel consulted with the client to determine the actual Business Continuity requirements to keep the business active within the FCA Regulatory Framework. Consideration was given to how Orders and working Trades would be dealt with if a DR event occurred.
An critical aspect of the Business Continuity plan is whether it will pass Investor Due Diligence as well as work for the business and the Regulator.
IP Sentinel constructed a plan that satisfied all the stakeholders and worked for the business itself.
The physical implementation of regulatory Archiving with a Mimecast email service also provides a full Business Continuity wrapper.
IP Sentinel engaged with the clients “Private Cloud” provider and wrapped Mimecast around the existing Exchange and Office 365 implementation. This was a seamless provision with no interruption to email services.
To store Bloomberg IM and MSG traffic IP Sentinel put in place a daily download from the secure Bloomberg Compliance service to an archived storage area.
The phone recordings are also stored in the same vault but with a much shorter retention period.
The client is now fully compliant with the FCA SYSC Business Continuity and Archiving obligations