Work From Home in Coronavirus Era

1. Monitor Remote Work

2. Businesses are increasingly asking their employees to self- quarantine, practice social distancing and stay home. But, what if you’re a financial trades broker or firm, how do you monitor transactions, behaviors and eComms outside of your office? This virus may be thwarting efforts to socialize and attend large scale entertainment attractions, but it’s certainly not going to curb efforts to leverage the crisis for the purpose of perpetrating market abuse crimes. VOLATILE MARKETS ARE BUSY TIMES Formanyinvestors, volatilemarkets signalthatit’stimetoact. Theworld iscurrentlyhopefulthatthis pandemicwilleaseuponcethe summerstarts. And, asisthecasefor everyUSelectionyear, the instabilityofthemarketsinthe monthsbeforethevoteistypically replacedwithavigorousrallyonce anewPresidentisselected. Thiscouldbeabumpyride. Forhowlong, nobodyknows, but it’sgoingtoputadditionalstrainonglobalandlocal economies, aswellasonthepeople. ARE YOU READY FOR WORK-FROM-HOME? Manybusinesseshavenotyet draftedpoliciesthatmeet currentapplicationsof technologyandeComms, let aloneestablishedstrict protocolsgoverningmonitoring andsurveillanceintheeventof aglobalcrisis.

3. HOW TO DEVELOP A CONTINGENCY PLAN AS A FINANCIAL INSTITUTION Asitisthecasefornearlyeverything, yousimplydon’tknowwhat youdon’tknow…untilyouknowthatyoudon’tknowit. That’sa ratherconvolutedwayofstatingthat, becauseyoucan’tbeready foreverything, youneedtoconductascenarioplanningexercise thenestablishacontingencyplanforasmanyscenariosas possible. Butwheredoyoubegin? Audit everything. Conduct an inventory of every mobile phone, laptop and IoT device on your network. Who owns it and, if it’s an approved device, what software is on it? If it’s not approved, obviously immediately disable access. This will take considerable time. In parallel, begin generating a list of “acceptable” or approved software and applications for any IoT device connected to your firm’s secure network. Create a detailed roster beginning with a registration list of all employees, their physical home address, home phone, and mobile phone numbers plus their supervisor’s home address, home phone, and mobile phone numbers. All titles, registrations, and lists of approved business activities must be captured. If any employee has had a history of discipline problems or coronavirus compliance violations, consider restricting remote access for those employees. Enable an onsite and remote work inspection team. Ensure that they have the required authorizations and systems access to conduct their inspections. Enablement includes providing a clear definition of how and how often these inspections will be conducted. Thesearechallengingtimes. It’sunclearhowlongitwilltakefor financialinstitutionstoreigninalleComms, tradesandother businessfunctionsforappropriatesurveillanceoperations. However, asystematicapproachtodefiningyourfirm’sbusiness practicesandthetechnologiesusedtoenablethosepractices canhelpyounavigatethisongoingmarketstormandprepareyou forthefutureofworkwhichisincreasinglytiltedtoworking-from- home. www.shieldfc.com