Recommendation - Model of a Direct Trading Operation

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The fall of some traders came as a result of numerous deficiencies in the control environment at Allfirst’s treasury. No single deficiency can be said to have caused the entire loss. To summarize, the following three major deficiencies in the control system have played a major role:

· Deficiencies in Trading confirmation

· Mid-Office control system not independent from the control system Front Office

· Inadequate resources in internal audit and risk control


From this information we have developed the following system for a direct dealing operation in close relation to the “Guidelines for Foreign Exchange Trading Activities – September 2001” from the Foreign Exchange Committee of the Federal Reserve Bank of New York. More about Foreign Exchange


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