March 18, 2019

UBS have been fined £40 million (reduced to £27.5 million) because “UBS breached the requirement for firms to submit complete and accurate transaction reports.”

Reporting Issues

  • Between 5 November 2007 and 24 May 2017, UBS:
    • failed to report 3,658,423 transactions (SUP 17.1.4R)
    • inaccurately reported 83,074,015 transactions (SUP 17.4.1EU and SUP 17.4.2R)
    • erroneously reported 49,152,274 transactions (SUP 15.6.1R)
  • 42 distinct errors identified
  • These issues were equivalent to approximately 7.5% of all transaction reports submitted by UBS during this time.

Systems/Processes Issues

  • breached Principle 3 – requires firms to take reasonable care to organise and control their affairs responsibly and effectively, with adequate risk management systems
  • failing to have adequate systems and controls to ensure that reference or ‘static’ data used for various mandatory fields in the transaction reports submitted to the Authority were complete and accurate
  • failing to have in place adequate change management controls to manage changes affecting transaction reporting processes and systems
  • failing to undertake appropriate testing to ensure the completeness and accuracy of transaction reports
  • “The Authority encourages firms to regularly validate static data to ensure its integrity”
  • “UBS’s framework did not adequately test and reconcile the completeness and accuracy of all transaction reporting data from its front office systems to the ARM reporting to the Authority”