Five Innovative Strategies for Resilient MiFID II Reporting

Steve Barnes, CTO

In our previous blog, we took time to pause, reflect and consider some lessons learned from the compliance processes for MiFID II transaction reporting. In this blog, we take a step further and look at five ways innovation can create a resilient MiFID II transaction reporting framework.

In his speech of 3rd July 2018, Mark Steward, Director of Enforcement and Market Oversight at the Financial Conduct Authority, stated1 that the FCA now processes over half a billion transaction reports per month, coming from 23 submitting entities, representing 3,150 firms.  The FCA has invested heavily in its technical capacity to ingest, process and analyse the information reported. In its transaction reporting forum from July 2018, the FCA provided further analysis on the quality of those transaction reports, highlighting the major sources of rejection rates. Duplication, content validation and instrument validation errors feature highly in the top ten.

From this analysis, it is clear that a resilient framework is required to achieve robust reporting. Effective use of technological innovation can help achieve this by enabling firms to harness data to proactively monitor, identify, and correct situations that can lead to poor outcomes.

Here are five key areas where innovation can make a difference.

  1. Data is imperfect. In order to achieve the accuracy requirements, firms need a realistic, flexible process for managing data. This can be achieved by combining APIs or automated data feeds from trade repositories with user self-service, in-application data management and maintenance functions. A well-designed self-service intelligent reporting platform will usually have data preparation tools that store, manage, and provide access to source data, prepared data, and data models, with appropriate governance measures. This helps reduce the headache of managing all data ‘at source’.
  2. Don’t be an outlier with high rejection rates. Industry rejection rates have been cited at 5% of total reports submitted. Not only is it undesirable to be identified by the regulator has having poor accuracy, dealing with high volumes of rejections can also be operationally burdensome. Early validation is key to achieve accuracy. Validate the data at each point; on loading, on processing and on generation of XML to be submitted to the regulator. Inaccurate data should not pass through these three gates. At AQMetrics, we see a rejection rate at less than 0.5%. This is achievable for all firms and submitting entities.
  3. Leverage external data sources to your advantage. Industry available external data sources are maturing. The GLEIF2 infrastructure has achieved excellent levels of stability since launch date. DSB ANNA3 and FIRDS4 have continued to mature over the course of the year. The commitments from ANNA and GLEIF to link ISINs to LEIs in an effort to assist with accurate reporting, will further strengthen the quality of external data sources that can be leveraged to the firm’s advantage. An intelligent reporting platform will integrate these sources, and will leverage appropriately in the validation process.
  4. Timing is key. Validating the data early in the process, rather than downstream at reporting time, can eliminate bottlenecks at the t+1 deadline. The rise of the Intelligent User Interface (IUI), stemming from breakthroughs in machine learning, allows intelligent user prompting. Timely alerting of critical path issues via secure mobile applications can help prevent end-of-day delays.
  5. Achieve continuous reconciliation. In accordance with regulatory technical standards, the firm’s reconciliation responsibilities include checking the timeliness of the report, the accuracy, and the completeness of the individual data fields. Reconciliation should be on-demand, continuous and part of ‘business as usual’ daily processing.  Firms can achieve this with configurable data analytics dashboards, where multi-dimensional data insights can drive improved reconciliation processes.

Finally, resilience is achieved through a combination of these innovation strategies. With this kind of approach, the reporting framework becomes stronger and can be augmented further to provide data insights beyond the original purpose of the reports. Intelligent user interfaces, machine learning and data analytics are now becoming widespread. The careful application of these technologies will lead the industry into an era of rapid learning and improvement, and ultimately a stronger foundation for compliance.


How to prove your UCITS Fund is not Index Hugging

With more than 2,000 Irish investment funds facing into Central Bank of Ireland (CBI) investigations to ensure they are not misleading customers about charges and other issues it’s important to ask how these firms can best provide regulators with the proof that they need.

The CBI investigations into UCITS funds have been sparked by concerns raised by the Paris based European Securities Markets Authority (ESMA). Yet this is not a new area of concern for the CBI. The CBI’s 2016 report sought to ensure that customers were not misinformed about UCITS’ investment policies and charges. As a result UCITS funds are well briefed on the concerns of the CBI.

The CBI recently announced, of particular concern is “closet indexing” or “index hugging”. This is where the fund managers falsely claim they invest actively to get better returns than those offered by stock exchanges, but in fact they take a more passive approach and track a benchmark index which in turn results in returns matching those of the markets.

As there is more work for an active fund manager to actively place trades to generate higher returns, they can charge higher fees. A passive strategy which simply keeps pace with stock market returns requires fewer trades, and therefore means that the manager should charge less. The CBI is investigating if this is indeed being carried out in practice.

The burden of proof is on the fund manager. They must be able to show that they have been actively trading and can use best practice techniques such as automated trade monitoring and auditing software to prove that they are not merely tracking the index. Savvy fund managers will take this a step further and provide data visualisations to the CBI that show fund performance when compared to an index benchmarks and additional automated data insights that show the variances between the fund and benchmark. It is clear that technology is the solution to the now ongoing burden of proof that UCITS fund managers face.

With 2000-plus Irish domiciled UCITS funds to investigate the task facing the CBI is by no means insignificant. It is therefore likely if the regulator finds proof of “index hugging” it may use all its powers, which include ongoing supervision and sanctions such as fines. For this reason UCITS fund managers need technology to lessen their burden of proof and maintain a good relationship with their regulator.


MiFID II Reporting – a year of light and shade

Claire Savage, Chief Operating Officer, AQMetrics

Following years of planning and implementation for MiFIR,  it is time to pause and consider the lessons learned from the compliance process and the ongoing considerations in this evolving regulatory environment.

The reality of being in implementation mode for MiFID II for the last two years, preceded by almost ten years of regulatory reform, is that the reporting solutions put in place have been tactical, and found lacking in certain areas. While the target goal for transaction reporting by 3 January 2018 was met by most firms, the challenge of meeting accuracy, completeness and reconciliation obligations is slowly evolving.

The National Competent Authorities (NCA) too have experienced a period of adjustment and are entering a phase of optimisation. The Central Bank of Ireland’s recently published 1refers to a three period of consolidation following the implementation of international and European regulatory reforms. This relative lull in the introduction of new regulations represents an opportunity for firms to shift their focus towards optimising solutions around MiFID II and MiFIR.

Transaction reporting in an opaque environment

MiFID firms have undertaken transaction reporting with a commonality of data challenges. The collection and verification of expanded data sets, including legal entity identifiers, personal entity identifiers, and underlying instrument classifications, is compounded with the ongoing development and enhancement of external data sources, including the ESMA Financial Instruments Reference Data System (FIRDS) and the ANNA Derivatives Service Bureau (DSB).  

Tactical solutions involving manual workarounds have been largely deployed to help counteract these challenges. However, the risk with such tactical solutions results is that transparency is compromised, change management is challenging, and it results in a fragile system, that is operationally burdensome on the compliance team.

Shining a light for the future

There is no doubt that the regulatory themed inspections will increase in 2019, with a focus on completeness, accuracy and reconciliation for transaction reporting.

For completeness, while firms cannot solely rely on FIRDS as the golden source of data,  the process for identifying reportable and non-reportable instruments can be achieved by combining FIRDS reference data with supervisory controls for listing, determination and exclusion.  

For accuracy, data management can be addressed in partnership with the ARM,  through the provision of rule-based data management that may be absent from the firms’ legacy systems. Data can be collected, validated and consolidated with third-party data in the transaction reporting solution.

For reconciliation, transparency is key. Reporting statistics and flexible search functionality can be combined with peer group analysis to provide additional data insights to the firm.

Now is the time for firms to ask the following questions both internally and to their ARM:

  • How resilient is the MiFID II transaction reporting solution?
  • How can I consolidate this reporting with other areas of regulation?
  • How can I improve the processes and the controls within my firm to manage these regulations so that I am managing them with a common supervisory control portal?

The changing light

In parallel, this phase of optimisation is likely to be interwoven with shifting priorities in the european regulatory authorities.

In its strategic plan, the Central Bank of Ireland stated that ‘for MiFID firms, the landscape is changing’ and that the focus for regulators would be on ‘third party outsourcing, critical business operations, financial and technology information and, of course, Brexit’.

The UK has published a draft 2 to ensure the MiFID II and MiFIR regime works after Brexit. This will impact the transaction reporting requirements for both UK firms and European Economic Area firms with UK branches themselves and UK branches of European Economic Area firms. UK branches of EEA firms will potentially be subject to a double reporting requirement in some cases, and will need to adapt their reporting solution to facilitate transaction reporting to both the FCA and their home state NCA.

What is assured though, is that the EU will continue to take all steps necessary to protect its market. With MiFID III on the horizon,  there is no doubt that there are shades of grey ahead. Now is the time to pause, reflect and optimise. The tactical implementations may have served their purpose in 2018, but for 2019 onwards, a more strategic approach is required. 

Would you like to learn more? Sign up here to receive the next blog in your inbox.

Blog, Buzz, Press

AQMetrics recognised in top 100 RegTech firms for second year running

DUBLIN and London, 29 November 2018AQMetrics, the award-winning provider of regulatory compliance and risk solutions, is honoured to be included in the RegTech 100, as one of the world’s most innovative RegTech companies.

The RegTech 100 list acknowledges companies for their innovative use of technology to solve a significant industry problem, or to generate cost savings or efficiency improvements across the compliance function. A panel of analysts and industry experts evaluated 824 companies to arrive at this year’s list, which at nearly double the number of companies in consideration last year, highlights the rapid growth and competitive nature of the RegTech industry.

“To once again be listed as one of the top 100 RegTech companies is a vindication of our vision to become the leading Global RegTech company,” said AQMetrics CEO Geraldine Gibson. “Our commitment is to continue scaling the AQMetrics online and mobile platform for global risk and regulatory reporting solutions. We believe that AQMetrics connected platform is the foundation for solving the regulatory burden faced by our wide range of customers from banks through to individual investment managers.”

A full list of the RegTech 100 is available at

About AQMetrics

AQMetrics is a leading RegTech company focused on delivering regulatory risk and compliance solutions for financial professionals. We recognized that the accepted methods of managing risk and compliance were slow, outmoded, and inefficient. We drew upon our team’s deep experience in innovation, technology, law, and financial services to build a platform that performed markedly better, helping our clients leverage technology to more efficiently meet regulatory obligations. The AQMetrics platform has been tested, proven and perfected.

More information is available at or follow us on Twitter @AQMetrics

Media contact
Phoebe Toal, AQMetrics,

Blog, Buzz

Meet the Team- Jody Collins

At AQMetrics we have a highly skilled, experienced and diverse workforce with wide ranging backgrounds.

Each month, we introduce you to a member of our team. This month it’s Jody Collins from our Customer Success team.



Jody Collins, Product Analyst, Customer Success Team.

Describe your job in three words:

Agile, Diverse, Collaborative

What is the most exciting thing you are working on?

I like bringing new AQMetrics products to customers and exceeding their expectations. Working with customers to draw out their requirements and feeding this into our product road map, is a key part of my role.

How has your background helped with your role in AQMetrics?

My background in computer science and my broad experience in business intelligence has positioned me well for this analyst role on the customer success team. I have a passion for seeing customers’ desired outcomes realised as part of the product road map process.

Best thing about working in AQMetrics?

Meeting and talking with customers on a daily basis and working within the close knit, supportive AQMetrics team.

Who would you most like to swap places with for the day and why?

Tim Ferris because he delves into areas that are completely new to him. On his podcast, he probes his interviewees so effectively, and has an exciting role as an angel investor in some really innovative startups.

Last book you read?

Michael Lewis Flash Boys, about high frequency trading.

Website you visit the most?, for home decor inspiration.

Tell us something we don’t know about you. 

I have travelled to 30 countries, my favourite being the Philippines.  


How the new Securitisation Regulation 2017/2402/EU will impact AIFMs and UCITS in 2019.

Regulation (EU) 2017/2402 (Securitisation Regulation) introduces new internal monitoring and reporting challenges for institutional investors. EU AIFMs are already subject to internal monitoring and reporting in relation to securitisation positions under the EU Alternative Investment Fund Managers Directive 2011/61/EU (AIFMD). As of January 1, 2019, due diligence, transparency, and risk retention requirements will also impact both UCITS and non-EU AIFs in securitisation positions. How will they be impacted is the question that we look to answer here.

It is worth noting that from 2019 on, if an institutional investor (such as an AIFM or UCITS manager) delegates responsibility for fulfilling due diligence, monitoring, and reporting requirements, then any sanctions may be imposed on the delegate rather than the institutional investor.

With the possibility of sanctions in mind, institutional investors and their delegates will need to use systems to verify that the originator of credit has also used an effective system to stress the underlying exposures and, in so doing, ensure that the credit is sound. Just as the money laundering directives brought rules-based systems to the fore for money laundering reporting officers (MLROs) and compliance officers, rules-based systems will also now be at the fore for both AIFMs and UCITS managers to robustly support securitisation due diligence checks.

A robust rules system will combine factor analysis with exposure calculations for risk assessment; have rules based on specific limits (such as the 5% rule which is applied to verify that the sponsor, originator and original lender retains at least 5% economic interest throughout the securitisation’s lifetime); and perform stress tests.

Data points required for rules analysis will no doubt extend further than the payment, credit and liquidity details captured today. Further data analytics will be required to capture cash flow trends, late repayment trends, default rates and frequency of loan modifications.

Once the data and data analytics are in place, institutional investors will further require management and regulatory reports on securitised positions and associated exposures. It is anticipated that from 2019 onwards, regulators will increase their interest in the verification workflows, audit trails and record retention of AIFMS and UCITS managers with regards to securitised positions. Automated corrective action workflows will somewhat support the institutional investors, however manual tasks will still be required to ensure that the UCITS manager acts in the best interest of the investors at all times and that the AIFM has truly validated that its corrective action is the best course of action available at a specific point in time. No doubt regulators will look for proof that these manual tasks were completed and that even data pertaining to manual tasks was comprehensively and consistently captured in a robust system.

To date, neither UCITS firms nor non-EU AIFMs may have given much thought to how best to comply with the securitisation regulation, but that must change by January 2019. Systems with rules engines, workflow, audit trails and reporting will become the new norm for UCITS and non-EU AIFMS going forward.

Blog, Press

Claire Savage talks to the Financial Technologist about Fintech and Diversity

Recently COO Claire Savage sat down with the Financial Technologist, as part of their champions of diversity series.

At AQMetrics, we strongly believe that diverse teams produce the best results. Our team is solving complex problems with software solutions for the global asset management industry. We recognise and draw upon neurodiversity within the team which comes from differences in gender, age, ethnicity and socio-economic backgrounds.

With diversity comes non-linear thinking, a valuable trait for any problem solving roles.

Read the interview here.



Data: Asset or Liability – regulatory compliance data innovation

By Wesley Cooper, Data Architect, AQMetrics

In this series of blog posts, we explore how the next generation of intelligent regulatory reporting solutions are delivering insights far beyond their original purpose.

This second feature in the series looks at the importance of managing data as an asset, and hidden risks that should be mitigated to prevent it becoming a liability.

The wave of complex regulatory compliance requirements, combined with advancements in ‘big data’, has created an explosion of data that financial services firms collect, store and report. In our previous blog, we looked at how to maximise the data asset. In this post, we look at how to ensure it does not become a liability.

Big data is slowly beginning to fulfill its immense promise but new regulatory constraints and ever shifting business needs have left some firms unsure of how to appropriately manage this data. While the default position in your firm may be to hoard all data for future use, it is increasingly becoming more important to ensure the quality of this data is assured, and the techniques for interrogating this data are sound.

Data governance by design

There are certain principles of data governance that all firms must follow to fulfil their responsibilities as a data controller and a data processor. While the implementation of the General Data Protection Regulation (GDPR) was an additional regulatory burden for most firms in 2018, it has driven best practices for data protection. However, one key aspect of data governance, which can often be overlooked, is the requirement to continuously monitor the quality of data. Data is increasingly being gathered from alternative sources, and is being aggregated with data from multiple origination points. Quality assurance processes must be ingrained in the firm’s culture and managed as a continuous process, as the data moves from the front office to the back office. This is not a once-off task, it is a firm-wide responsibility to ensure data is accurate, cleansed, standardised and profiled correctly.

Another important factor for successful data governance is adopting a partnership approach to data quality assurance between the data owner and the data processor. A data processor, with cross-market insights, can apply outlier analysis and peer group analysis to identify data anomalies and quality issues that may be invisible to the data owner. A strong relationship between the data owner and a data processor will foster feedback loops to ensure continuous quality improvement.

Data denial – proving the in-house hypothesis

The abundance of available data, combined with the proliferation of complex big data tools, is dramatically changing the way firms manage data. Misuse of large data sets and big data intelligence tools can produce misleading results that impair, rather than enhance, decision making. This can be adversely amplified with confirmation bias – an internal “yes-man” per se. It is human nature to filter results or interpret data in a way that confirms existing preconceptions and ignore any contrary insights. Ignoring such insights and choosing the results that best align with corporate groupthink can create false feedback loops and ultimately prevent firms from unearthing the true insights hidden in the data.

By falling victim to these traits, can we reasonably expect to identify when a black swan event becomes a market event?

The Future

In the financial services industry at present, there is significant interest in the future use of machine learning and artificial intelligence for regulatory compliance. The use of these technologies is appropriate in certain circumstances, for example natural language processing lends itself to fuzzy logic and semantic algorithms. However, the misuse of these technologies can be a liability, for example the creation of large volumes of false positives in pattern matching. A key advantage to any machine learning system should be the ability to filter out any analytic models that are inappropriate for a given data set, until the right one (or at least the best fit) is qualified. This decision-making process can be based on any number of data attributes, such as its probability distribution for example, and can largely mitigate the risk of the aforementioned error propagation.

Implementation of these technologies will ultimately only be successful if the other fundamental elements of data governance and data model design are executed carefully. Data can be optimised as an asset when it is used to communicate insights clearly, at the point of highest impact, with a sound legal basis to do so. Anything less is a missed opportunity at best, and a costly, potential liability at worst. The work required to implement the right process may seem like a daunting task, but the rewards are plentiful.

Would you like to learn more? Sign up here to receive the next blog in your inbox.


Meet the Team – Andrew Fox

Meet the Team

At AQMetrics we have a highly skilled, experienced and diverse workforce with wide ranging backgrounds.

In a new series, we introduce you to our team. First up is Andrew Fox.




Andrew Fox, Senior Quantitative Developer

Describe your job in three words:

Focused, challenging, rewarding.

What is the most exciting thing you are working on?

Big data analytics and the multiverse that is financial risk.

How has your background helped with your role in AQMetrics?

My background was originally theoretical physics which then evolved into computer science, so my current role as quantitative developer couldn’t be more appropriate.

Best thing about working in AQMetrics?

The team makes it. Everyone is open-minded, down to earth, good humoured and most importantly willing to help anyone else at the drop of a hat. It’s a great environment for productivity, and a notable factor in why we produce great software

Who would you most like to swap places with for the day and why?

Maynard James Keenan. Musically – the man’s a genius, and he also produces delicious wine. What’s not to love.

What was the last book you read?

It was more of a short story – “The Last Question” by Isaac Asimov. It’s quite profound , and I’d thoroughly recommend it.

What websites do you visit the most?

Carzone probably – I have an urge to buy a classic vintage car at the moment.

Tell us something about yourself we don’t know.

I’m a classically trained tenor.


How to turn data into diamonds – regulatory compliance data innovation

By Steve Barnes, CTO

In this series of blog posts, we explore intelligent regulatory reporting solutions and how the next generation of  solutions are delivering insights far beyond their original purpose.

This first feature in the series looks at the importance of data innovation, and the hidden value that can be realised from data assets.

Changes to regulatory reporting regimes have focused attention on the process by which data is gathered. Distilling fund data into a format that can be used for regulatory reporting is a challenge for managers, particularly those whose funds are administered by more than one fund administrator. However, once this data is gathered into a golden source, not only can it be deployed for global regulatory filings, it can also be extended, reused and redeployed to provide additional insights, far beyond the original intent.

The ultimate asset – a Golden Source of Data
Since fund data is stored in multiple systems and these source systems rely on multiple formats, it is little wonder that managers yearn for a single, consolidated view, otherwise known as a ‘golden source’. This desire has been amplified by managers’ increased reporting requirements.

Firms are recognising that they are becoming data-driven organizations. Data is being treated as an asset, and optimised to the maximum, as any other company asset. The concept of data as an asset is not only being recognised by the firms themselves, it is also being acknowledged by the regulatory authorities. Recently when the Central Bank of Ireland deputy governor – Ed Sibley, made a keynote speech on this matter, he highlighted “firms that can harness data effectively can expect competitive advantages”. 1

However, attempts at harnessing data are often hampered by the restrictions and shortcomings of the source legacy systems. Firms need to see beyond the legacy system constraints. Automated rules for data consolidation, enrichment and normalisation can be executed to transform the data into forms ready for regulatory reporting, and also into a format ready for further exploration and insights. These rules, often executed in locations outside of the source systems, allow for third party data enrichment, data quality issues can finally be addressed and importantly, allow for a flexible translation for multiple downstream requirements.

Think of data transformation as as control mechanism to get your data into the required shape for multiple uses. A flexible rule system can easily accommodate this.

Value in data insights beyond regulatory reporting
An additional benefit of the ‘golden source’ approach is that data will not only be optimised for regulatory reporting – it can also be fed into cluster computation engines, such as Apache Spark, to reveal previously hidden business intelligence insights.

However, having insights into your data is only part of the solution. Effective communication of those insights is what makes information actionable. It is important to consider the correct visualisations and level of configurability required by customers to ensure that insights are received clearly, at the right time, to impact decisions in the best way possible.

The insights and competitive advantage that firms can realise from their golden source of data are vast and unlimited. Often firms will use regulatory reporting data to perform variance analysis against the submitted regulatory reports across filing periods and jurisdictions. Increasingly we are encouraging our customers to use this data in configurable dashboards to perform trend analysis against holdings and exposures, across sectors, geographies and asset classes and to calculate performance metrics against cumulative returns in order to track portfolio performance against appropriate benchmarks. Such measures, to mention a few, include Alpha, Beta, Sharpe and Sortino ratios, and drawdown related quantities, such as the maximum drawdown and recovery rates over given time periods.

Enhanced data-driven decision making with Machine Learning
What was key in Mr Sibley’s speech was that the use of artificial intelligence and machine learning can be very powerful. We ask the question, what is your data trying to tell you that you are not even looking for at present?

In the AQMetrics innovation lab, we are applying machine learning to drive new insights beyond the typical variance analysis that has become de facto.

Outlier analysis
Using historical data analysis insightful data items can be uncovered using machine learning algorithms. These algorithms learn what is usual for a set of regulatory reporting data and highlight where something falls out of normal bounds. Both univariate and multivariate outliers can highlight data errors, but also importantly, in the multivariate case, it can highlight clusters of outlying data, which could potentially be indicative of a more elusive market event; hence the need for contextualizing the outlying data for individual firms. Analysis can point out large movements in a manager’s funds or erroneous data in the reporting of these funds to the regulator and most importantly – before the information is reported to the regulator.

Peer Group Analysis
Peer group analysis offers new possibilities with the increased use of multi-tenanted cloud platforms. Opt-in, anonymised analysis can compare an individual manager’s funds with other funds which share a similar investment strategy. Rolling up data into a global view across a diverse set of funds can provide exciting ways for managers to evaluate their own funds. Trends and movements across securities, returns, exposure, geographical locations and sectors can highlight efficiencies and areas of improvement for funds to improve their own data and workflow processes. It is through the increased pressure of these processes upon a firm’s data that can turn data into diamonds.

1The need for resilience in the face of disruption: Regulatory expectations in the digital world – Deputy Governor Ed Sibley 03 October 2018 Speech

In the next blog we will look at data as both an asset and data as a liability. We will explore the processes, workflow and third party controls that every firm needs to protect their data assets throughout the regulatory compliance journey.

Would you like to learn more? Sign up here to receive the next blog in your inbox.


AQMetrics Drives Future Growth With Three New Senior Hires

DUBLIN, LONDON and NEW YORK, 9 July 2018 — AQMetrics, a leading Software as a Service company, today announced it is growing its senior team with the addition of Barry McCarthy as CFO, Rishi Thapar as Risk Manager and Atishma Vashisth as Director of Business Development, UK.

The company has appointed Barry McCarthy as Chief Financial Officer with overall responsibility for shaping AQMetrics global financial strategy. A chartered accountant with extensive experience in financial services, regulatory reporting, M&A and key stakeholder communications, Barry joins AQMetrics from ITG, a publicly quoted global financial technology company, where he was EMEA Finance Director. Barry trained with EY where he predominantly worked on the audits of large multinational software companies.

Rishi Thapar is a renowned Risk Specialist. Rishi is joining AQMetrics as Risk Manager responsible for the extension of AQMetrics performance attribution and Risk as a Service offerings. Rishi was most recently Senior Risk Manager at Windmill Hill Asset Management Limited and established the risk management function in the company. Prior to that he was Director of Risk at UBS, Risk Manager at Armajaro Asset Management LLP and Senior Risk & Quantitative Analyst in International Asset Management Limited. He has written several publications including ‘Applying a Global Optimisation Algorithm to Fund of Hedge Funds Portfolio Optimisation‘ and ‘A risk measure for S-shaped assets in option valuation and in predicting performance of hedge funds’.

Atishma Vashisth has joined AQMetrics as Director of Business Development, UK. Atishma has both buy-side and sell-side sales experience and has covered global markets including Asia, Middle East and USA in her previous roles at IHS Markit and Factset Group where she was responsible for risk product sales. Her risk product knowledge spans across multi-asset portfolio, counterparty credit and market risk analytics. These latest hires reinforce the firm’s commitment to attracting industry-leading talent to supporting the growing global adoption of its award-winning cloud-based Software as a Service (SaaS) platform.

Geraldine Gibson, CEO of AQMetrics commented “We are entering an exciting phase of AQMetrics growth. I am delighted to welcome Barry, Rishi and Atishma, who between them have quantitative risk analysis, enterprise sales and financial services experience. This blend of skills are strategically important as we seek to respond to global demand for integrated risk and regulatory solutions.”

*** END ***

About AQMetrics
AQMetrics is an award winning Software as a Services company focused on delivering risk and regulatory reporting solutions to global investment firms. AQMetrics replaces slow, outmoded, inefficient and oftentimes manual methods of managing risk and regulatory reporting. Through its unique blend of deep experience in innovation, technology, law, and financial services AQMetrics has built a platform that performs markedly better, helping AQMetrics clients leverage technology to more efficiently meet risk management and regulatory reporting obligations. The AQMetrics platform has been tested, proven and perfected.
More information is available at or follow us on Twitter @AQMetrics


AQMetrics named one of the hottest Fintechs in Europe

AQMetrics is delighted to be included in FinTechCity’s FinTech50 list for the second year running. Recognised on the list of the hottest Financial Technology firms to watch for the coming year, The FinTech50 is selected by an international panel of FinTech experts and is seen as a guide to quality and innovation within a very crowded sector.

AQMetrics’ CEO Geraldine Gibson commented, “There were 1,800 firms considered by the judging panel for this list, so we’re absolutely delighted that AQMetrics has been featured for two years in a row. This is a recognition of the innovative work we’re doing in the areas of risk and regulatory reporting”.

The full list is available at

Market Data, News

AQMetrics Extends Platform to Provide “Golden Source” of Market Data for Enhanced Risk Analytics

Partnering with multiple providers to create market data lake across different asset classes

DUBLIN and NEW YORK, June 6, 2018

AQMetrics, the award-winning provider of regulatory compliance and risk reporting solutions and authorised Central Bank of Ireland Approved Reporting Mechanism (ARM), today announced the extension of its platform to include a “golden source” of market data for in-depth pre-trade and post-trade risk analytics and regulatory reporting. By partnering with a number of global market data providers, AQMetrics’ customers now benefit from an extensive market data lake.

During the past year, to support a growing demand for its risk and regulatory reporting solutions, AQMetrics has been heavily investing in its Apache Spark based platform, architected to manage the largest exchange, trade and market data sets at great velocity. The firm has now also partnered with a number of market data providers across multiple markets and jurisdictions, to bring together the comprehensive data repository on which it now bases its risk analytics.

Geraldine Gibson, CEO at AQMetrics commented, “AQMetrics is well placed to leverage our approved reporting platform and transaction processing technology to meet the increased regulatory focus on detection and control in a pre- and post-trade environment. An example of the increased regulatory focus in this area is the recent FCA Report on Algorithmic Trading“. She added, “Combining our platform with a golden source of market data from a wide range of vendors, we are able to deliver a even more comprehensive analytics and reporting solution.”

The market data repository will also enable AQMetrics to run more advanced analytics for its clients, providing a deeper and wider view of the market and potential detection of anomalies in high frequency and algorithmic trading activity.

AQMetrics is very pleased to have been awarded several industry accolades over the past year including the most recent as Best Technology Firm from CTA Intelligence US Services Awards 2018, awarded to service providers to the US managed futures industry that have demonstrated exceptional customer service, innovative product development and growth over the past 12 months.

About AQMetrics

AQMetrics is an award winning RegTech company focused on delivering risk and regulatory reporting services to global investment firms. AQMetrics replaces slow, outmoded, inefficient and oftentimes manual methods of managing risk and regulatory reporting. Through its unique blend of deep experience in innovation, technology, law, and financial services AQMetrics has built a platform that performs markedly better, helping AQMetrics clients leverage technology to more efficiently meet risk management and regulatory reporting obligations. The AQMetrics platform has been tested, proven and perfected.

AQMetrics was recently awarded ‘Best New Technology Introduced over the last 12 months – Risk Compliance and Reporting’ at the 2017 Waters Technology Awards, ‘Best compliance product for small and start up firms’ at the 2017 HFM US Technology Award and was noted as a ‘Most Successful FinTech’ at the 2017 Euro Finance Tech Awards.

More information is available at or follow us on Twitter @aqmetrics.

Blog, Market Data, Technology

Effective Data Management in a Fragmented Market

By Breige Tinnelly, AQMetrics

Our recent conversations with compliance and risk managers at investment management firms have highlighted a common pain point, which is how to put in place the right kind of technology platform to cater for both existing and future regulations. While their focus has naturally been on the most pressing compliance concerns ushered in under MiFID II, AIFMD and SEC Modernization (to name but a few) the reality is that a piecemeal approach to compliance is unsuitable for the fragmented regulatory changes that the industry now faces. And fragmentation exists on a number of levels, not only in the various rule changes at both the national and European levels, but also in the diverse approach market participants are taking when it comes to interpreting and implementing the various regulations.

One of the main problems we’re hearing is that investment firms need to focus on managing their day-to-day market risk and credit risk, but are now also being pushed by their investors to demonstrate they are effectively managing their operational risk as well. This is of course in addition to the increased regulatory requirements for transparency and increased oversight, with a number of significant changes scheduled for the first few months of 2018 alone. And we know from our close engagement with the market that the regulatory reporting demands of MiFID II alone already has many firms swamped.

Nimbler responses

The solution? Instead of adopting a quick change that is only effective in the short-to-medium term, investment managers need to be able to take a step back and adopt a long-term, holistic approach to the complex challenge of fragmented regulations and the need for greater risk control. That is where ‘as a Service’ technology, such as AQMetrics, comes into its own, by enabling firms to use the same ‘golden source’ of data, but for a variety of different purposes.

Beyond the piecemeal approach – a single ‘as a Service’ technology platform

At AQMetrics, our Data Management as a Service technology is created with one strategic goal in mind – to provide a single golden source of data that can be used for both our Risk as a Service and Regulatory Reporting as a Service technology. By handling a wide range of complex data across the board from a centralised hub – regardless of the size or type of firm – and adopting a standardised data management model, AQMetrics empowers organisations to respond to gain risk insights and regulatory change with greater agility, across multiple business functions. AQMetrics Risk as a Service technology, includes risk analytics such as VaR, the Greeks and Stress Testing, coupled with dashboards, alerts, workflow and audit functionality. We’ve also got Regulatory Reporting as a Service technology on our software platform and as an Approved Reporting Mechanism (ARM) under the Central Bank of Ireland, AQMetrics is a regulated entity, entrusted by some of the largest investment managers in the market to process all of their trade data for regulatory reporting.

We believe this holistic approach to ‘as a Service’ technology is the only effective way to truly tackle fragmented regulations and market changes head-on, regardless of what is coming down the road.


Risk Reporting challenges Algo Trading Firms

By Geraldine Gibson, CEO, AQMetrics

Sweeping new rules and technological advances have given regulators unprecedented insights into the markets they’re charged with overseeing. A constant stream of high-quality information from exchanges around the world is arming regulators with the analytics necessary to rigorously enforce this year’s MiFID II rules.

Gaining access to the same breadth of market intelligence can prove difficult for investment and trading firms. Market data vendors do a fantastic job of gathering and distributing data, but they typically specialise within particular sectors or markets, and are geared to meet the needs of specific paying clients. Consequently, data has become siloed and fragmented at many firms.

The FCA & algorithmic trading

It’s a troublesome situation, especially for firms engaged in algorithmic trading activity. This sector of the market has long been under scrutiny, increasingly so since the UK’s Financial Conduct Authority (FCA) published guidelines on algorithmic trading compliance in wholesale markets ( earlier in February 2018.

The FCA stressed the need for suitable and robust pre-trade and post-trade risk controls within the sector. This is where the question of data becomes key: Without deep, high-quality comprehensive market data, firms may be unable to gain the insights needed to monitor and respond to potentially illegal flaws in their algorithmic trading strategies. If they cannot do that, they leave themselves vulnerable to accusations of market abuse.  

It’s therefore imperative that they have access to analysis drawn from a deep lake of intelligence, one that can offer insights from across markets and asset classes. Ideally, a single source of data from which they can derive the same holistic market perspectives as their regulators.

This is where AQMetrics can help.

Golden big data source

We have spent the past years constructing a comprehensive data repository that is fed by market data providers from across multiple markets and jurisdictions. Through these partnerships we have begun coalescing pools of intelligence from disparate systems into one vast market data lake. From this golden source of data we can mine the raw materials to fuel more sophisticated and advanced risk analytics and offer deeper market insights.

Our Apache Spark architecture has been built to manage the largest exchange, trade and market data sets at great velocity. When combined with our award-winning risk, regulatory reporting and transaction processing technology, it offers exactly the infrastructure firms need in order to comply with regulatory best practice, giving them access to the sort of high-end insights and analytics that can help identify potential anomalies within their trading strategies. And through our real-time and audit-trailed alerts, they have the capability to maintain full control and reduce the risk of any such anomalies recurring.

No more grace period

The FCA’s publication has been interpreted in the market as a warning that firms engaged in high-frequency and algorithmic trading activity will be under the FCA spotlight throughout 2018 and beyond. From now on firms can expect the regulator to step up its monitoring and enforcement activities.

To ensure ongoing compliance with a regulator empowered by access to the most sophisticated market insights, it’s critical that companies have the mechanisms in place to utilize the deepest sources of high-quality data for regulatory and firm wide risk analytics.


Regulatory Reset: What Irish Funds Need to Know About CP86

By Lorraine Lyons, Business Development Representative

For the Irish Fund Management industry in the coming year, one regulatory change stands out: namely the introduction of the Fund Management Companies Guidance, or CP86. This far-reaching set of initiatives has of course been in the pipeline since 2014, when the Central Bank of Ireland (CBI) launched the consultation process, and so many of the elements outlined in CP86 should already be in place. However, the deadline for all Irish Funds to demonstrate their compliance with the new rules has now been set for 1 July 2018. In practical terms, this means that anyone sitting on the board of an Irish authorised UCITS management company, alternative investment fund manager (AIFM), self-managed UCITS or internally managed AIF needs to be aware of this new guidance – and have a plan in place for how to meet the new demands.

But what are the aims of CP86 and how is it likely to impact Fund Management (FM) companies in the country? According to the Central Bank of Ireland (CBI), the new rules are designed to underpin the achievement of substantive control” in the industry, with the aim of further supporting the existing supervisory framework for greater transparency and oversight of the Irish FM sector. And in order to be able to make this assessment, the CBI requires that all fund management company’s board minutes reflect its adherence to the six key compliance areas outlined in the guidance paper. These six areas are as follows:


  • Delegate Oversight. This relates to when a board delegates certain day-to-day data management activities to external third-party companies. In particular, it stresses that even when certain activities are delegated outside the firm, the board nevertheless remains ultimately responsibility in legal terms and must demonstrate that it still has oversight and control over those functions.
  • Organisational Effectiveness. One of the independent directors will need to take on this role to ensure that the company structure is kept under ongoing review. They should ensure it is appropriate for the size, nature and complexity of the firm and ought to be ‘change leaders’ who bring proposals to improve effectiveness to the board.
  • Directors’ Time Commitments. Directors are required to commit around 2000 hours to their role and to limit the number of directorships they hold in Fund Management companies.
  • Managerial Functions. There are six key managerial roles identified in the guidance and each of these must be assigned to individuals within the company, just as they are in other sectors such as banking.
  • Operational Issues. The CBI requires firms to retain records which can be readily retrieved. Thus if the Central Bank requests documentation from a fund management company before 1pm, it should be provided to the CBI on the same day, or by 12pm on the following business day if requested after 1pm. There is also a new requirement for fund management companies to maintain, and monitor daily, a dedicated e-mail address – and this should also be provided to the CBI.
  • Procedural matters. These are the details around how FM companies should apply for authorisation with the CBI, or if they are already monitored, how to maintain their relationship with the Central Bank.


In fact, the overall aim of CP86 is not to introduce a radical set of new regulations but rather to ensure compliance with the existing regulatory obligations and to allow the CBI to carry out engagement without constraint. So while firms may already meet many of these requirements, the new regulation now mandates that they document and demonstrate this in an appropriate and efficient manner. In order to meet these requirements consistently, firms should ensure they have a robust, secure and automated solution in place, which is specifically designed to meet these new requirements.

With the July 2018 deadline for compliance only a matter of months away, the time to be looking at your organisational structure, and thinking about the necessary changes, is very much now.


AQMetrics Receives Authorisation To Operate A MiFID II ARM

Central Bank of Ireland approves AQMetrics as an ARM under MiFID II

Dublin, 02 January 2018 – AQMetrics Limited, the award-winning RegTech that provides risk and regulatory reporting services across global regulatory regimes, announces today that it has received approval from the Central Bank of Ireland (CBI) to operate a MiFIDII Approved Reporting Mechanism (ARM), with effect from 3 January 2018. The authorisation permits AQMetrics to report MiFID firms’ transactions to National Competent Authorities (NCA) across Europe.

With MiFID II coming into effect this week, AQMetrics has been conducting testing of its ARM since the summer of 2017 and has also conducted end-to-end testing through the UAT environments of National Competent Authorities.

Geraldine Gibson, CEO at AQMetrics said, “AQMetrics was created to service both the buy and sell side of the financial services ecosystem. Detection of market abuse is a fundamental part of the AQMetrics solution set. As tracking and tackling market abuse is a key aim of MiFID II, being authorised to report transactions of MiFID II firms directly to all European regulators is a major milestone for AQMetrics. With clients including stockbrokers, banks and investment firms AQMetrics now seamlessly services both the buy and sell side for future and emerging regulations’.

Claire Savage, COO at AQMetrics added, “Not only does our authorisation confirm that AQMetrics has the operations, business continuity plans and information security management system required to operate as a regulated Approved Reporting Mechanism (ARM) under MiFIDII, it further endorses AQMetrics commitment to its clients to do everything it must to remain the gold standard, one stop shop, for regulatory reporting”. ”

***   END   ***

About AQMetrics

AQMetrics is an award winning RegTech company focused on delivering risk and regulatory reporting services to global investment firms. AQMetrics replaces slow, outmoded, inefficient and oftentimes manual methods of managing risk and regulatory reporting. Through its unique blend of deep experience in innovation, technology, law, and financial services AQMetrics has built a platform that performs markedly better, helping AQMetrics clients leverage technology to more efficiently meet risk management and regulatory reporting obligations. The AQMetrics platform has been tested, proven and perfected.

AQMetrics was recently awarded ‘Best New Technology Introduced over the last 12 months – Risk Compliance and Reporting’ at the 2017 Waters Technology Awards, ‘Best compliance product for small and start up firms’ at the 2017 HFM US Technology Award and was noted as a ‘Most Successful FinTech’ at the 2017 Euro Finance Tech Awards.

More information is available at or follow us on Twitter @AQMetrics

Media Contact

Lorraine Lyons

T: 353 1 903 5437



MiFID II:Articles

Dublin MiFID II Meetup: Time to Prepare and Prioritise

Dublin MiFID II Meetup

AQMetrics hosted its latest Dublin MiFID II meetup last week, just as the countdown to implementation has turned to the number of weeks and days remaining – rather than months. Co-hosted with Brown Brothers Harriman, the event brought the Dublin MiFID II community together to discuss how best to prepare for the changes being ushered in under the new rules. The timing of  the Dublin meetup was  significant,  following on from the Central Bank of Ireland’s review on suitability requirements. As a result, the regulator has urged firms to assess their individual requirements with their boards before 31 October 2017.

Call for clarity

Adrian Whelan, Senior Vice President of Regulatory Intelligence, Brown Brothers Harriman chaired a panel of leading industry figures as they reviewed where the biggest challenges lie. Ronan Gahan, Group CEO of Platform Capital Holdings, spoke on the previous lack of a MiFID representative body, and how some SME’s have struggled as a result with regulatory engagement. Transaction reporting was highlighted as a key challenge by Claire Murakami, Bank of Ireland, Senior Manager Business Controls, due in large part to the sheer amount of data involved. She also warned that a lack of clarity meant firms were at risk of having to re-work everything at a later date if they find their original interpretations of the rules were incorrect. Niamh Mulholland, Associate Director Regulatory, KPMG agreed that there is uncertainty around what information is required to fulfil regulatory obligations, but warned that regulatory engagement has been very detailed around the requirements and so firms will be expected to comply regardless.

Role of technology

In addition, Mulholland argued that although the need to build new systems is currently a burden, she also believed that those firms which invest in good technology now are going to be well placed commercially going forward. Having this data management infrastructure in place may well put firms in a good position, both in terms of enhanced cybersecurity and in terms of informing their business strategy, she said, adding that it was one of the few positive conversations taking place around MiFID II. Murakami agreed that technology investment is going to give certain businesses a ‘huge competitive advantage’. For example, a number of Tier One banks are planning to hook directly into the APIs of the Approved Publication Arrangements (APAs), allowing their dealers to access the data and see a real-time spread of what is happening in the market. This will of course also benefit their customers in terms of improved data analytics, she added.

Downside to transparency

However, while he welcomed incoming changes such as fee transparency, Gahan warned that the initial impact of MiFID II will be negative on market participants, but will benefit retail investors. Murakami agreed, predicting that its impact in the medium- to long-term will be negative – and that regulation in general is making us more siloed, drying up liquidity and creating a challenge to the globalization of market access. While increased information and good transparency is a good thing, Mulholland added that liquidity and fragmentation is likely going to be a real problem. That will be extremely disruptive, she explained, especially with Brexit coming up on the horizon as well.

What should firms be focusing on now?

Gahan believed the most important thing the industry could do ahead of the implementation date is to prioritise the areas which are likely to be measurable come January 2018. Murakami agreed, adding that firms should document and evidence all their efforts to show that they made every human effort to comply. Firms should also be focusing their efforts on their high priority and high impact areas, according to Mulholland – both from the business and the client perspective. And in answer to his own question, Whelan added that prioritisation is key, as there is of course a lot going on. However, he warned that it is the hard, binary things which firms should be focusing on getting right. If the market infrastructure is not there, then that is not their problem. Yet ultimately there is no longer any reason to delay on implementing the operational and reporting components, he concluded.

We will be holding further MiFID II events in London, New York and Dublin – for an invite please contact

Blog, MiFID II:Articles

MiFID II Meetup: What to prioritise for the next 100 days

Following the success of our inaugural London MiFID II meetup in July, AQMetrics hosted a second event in late September to work through some of the key issues in advance of the 3 January 2018. The event once again brought together industry professionals in a relaxed setting to better understand where to focus MiFID II priorities, as we enter this critical final stage before the new rules come into force.

Our expert panel, Stephen Hanks, Alicia Mellon, Jacqui Hughes, Robert Adler and Breige Tinnelly launched the discussions by identifying some of the most common MiFID II issues facing firms. The panel particularly looked at those issues not making the headlines but nevertheless of pressing concern to many in the industry, including the regulators themselves. Moderator Breige Tinnelly, Head of UK for AQMetrics, began by asking what challenges are impacting firms’ ability to plan and successfully comply with the new requirements – and if the market is truly ready for MiFID II implementation?

Seeking clarity

According to Alicia Mellon, Regulatory Reporting Project Specialist, Vanguard, one of the main issues lies in transaction reporting, particularly around the lack of guidance on corporate actions, with many on the buy side struggling as a result. In general, this lack of guidance from the European Securities and Markets Authority (ESMA) has resulted in Vanguard developing new systems, with a third-party vendor, based on guidance from the Investment Association instead.

Another area the buy side is struggling with is unbundling of research. Jacqui Hughes, Senior Regulatory, Risk and Change Management Consultant, KPMG, warned that the market had been hesitant to make any decisions – again due to a lack of clear guidance.   Robert Adler, Director of Business Development, Storm IT Financial agreed that unbundling is still a very big issue for the buy side, based on his interactions with clients, as is transaction reporting.

Causes for concern

However, for the larger investment banks, there are four common issues raised regularly with the FCA around MiFID II, according to Stephen Hanks, Manager of MiFID Co-Ordination for the UK’s Financial Conduct Authority (FCA), namely:

  1. IT build – In particular, where parts of their systems must interact with some other piece of legislation it is unlikely that systems will be complete in time for 3 January 2018.   
  2. Pressures caused by policy uncertainty – There is also concern about vendors delivering on time as well as ISIN testing and whether ISINs will be registered on time.
  3. Trading venue readiness – Some venues are only expecting to able to provide new rule books in December and that certain new functionalities will only be added very late in the day. The buy side’s ability to cope with that is fairly limited.
  4. Complaints about their clients – The sell side has limited confidence in the buy side’s ability trade report and do not believe firms are on top of this issue.

So given only three months to go, where should firms be focusing their priorities?

According to Hughes, there is a notable divergence between the size of firm and its capacity for MiFID II. This is a challenge for the smaller firms considering a new level of transaction reporting must be underpinned by the right data and, in her opinion, most firms have not taken a strategic approach due to a lack of time, money and resources. Adler also warned about the implementation times quoted by vendors, such as the 60 days needed to install a fiber cable. He believes firms must be made aware of this and that they need to be able to show the regulator that they are at least in the process of putting new systems in place to meet the data requirements.  

We will be holding further MiFID II events in London, New York and Dublin – for an invite please contact


AQMetrics attains ISO27001 Certification

AQMetrics achieves ISO27001 Certification reaffirming commitment to data protection

DUBLIN, 7th September 2017.  

AQMetrics- Leading RegTech company, AQMetrics, today announced it has received  the International Organization for Standardization’s prestigious ISO / IEC 27001:2013 certification. This announcement assures the company’s customer base, which includes global financial services organisations, with some of the most demanding security requirements in the world, that AQMetrics has the controls in place to protect their data at all levels.

ISO27001 is the international standard for providing requirements for information security management systems. Organizations that meet the standard are certified compliant by an independent and accredited certification body on successful completion of a formal compliance audit. While all data transferred to and from AQMetrics has always been protected, this third-party certification differentiates AQMetrics as going above and beyond to ensure that AQMetrics cloud based software is delivered and maintained to the strictest information security standards.

“Organisations using cloud based software service providers have understandable concerns about security when choosing a vendor,” said Geraldine Gibson, CEO at AQMetrics. “For our customers, these certifications provide further verification of our utmost commitment to security and trust. This commitment is part of the reason why investment managers, asset managers, brokers, fund administrators and banks rely on AQmetrics cloud based software to know their regulatory risks and always be compliant.”

Claire Savage, Chief Operations Officer at AQMetrics, commented, “In today’s regulatory environment, financial firms need the assurance that any and all data they are entrusting to third parties is fully secure. Further, in terms of GDPR, we believe this certification is essential for our clients, as the regulation will require firms to demonstrate that their data is being managed in accordance with data protection regulations both within their own organisation and with any cloud based software service providers they use.”

About ISO/IEC 27001:2013

ISO27001 is the international standard for management, control and continuous improvement of information security management systems.  This International Standard has been prepared to provide requirements for establishing, implementing, maintaining and continually improving an information security management system. The adoption of an information security management system is a strategic decision for an organization.

About EU General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). The GDPR aims primarily to give control back to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. It becomes enforceable from 25 May 2018 after a two-year transition period.

About AQMetrics

AQMetrics is a leading RegTech company focused on delivering regulatory risk and compliance solutions for financial professionals. We recognized that the accepted methods of managing risk and compliance were slow, outmoded, and inefficient. We drew upon our team’s deep experience in innovation, technology, law, and financial services to build a platform that performed markedly better, helping our clients leverage technology to more efficiently meet regulatory obligations. The AQMetrics platform has been tested, proven and perfected.

More information is available at, or follow us on Twitter @aqmetrics

Media contact

Lorraine Toland

AQMetrics Ltd