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TECHNOLOGY, AI & COMPETITION

Best execution

Best execution obligations are reaching into the Technology, AI and Competition sector through a convergence of financial market structure rules and emerging platform accountability frameworks, with the U.S. Securities and Exchange Commission, the U.K. Financial Conduct Authority, and the European Securities and Markets Authority each applying pressure on how algorithmic systems route, price, and execute transactions on behalf of clients. The SEC's Rule 605 and 606 overhaul, finalized in 2024, expanded disclosure requirements in ways that directly implicate firms using AI-driven order routing. Compliance teams are now auditing execution quality workflows to confirm their algorithmic vendors can produce the documentation those rules require.

Watch

  • SEC Rule 605/606 amendments: expanded venue disclosure deadlines for order routing systems
  • FCA's multi-firm review of algorithmic execution quality in wholesale markets, findings expected 2025
  • ESMA MiFID II best execution RTS 27/28 reinstatement proposals still pending Council sign-off
  • AI vendor contracts: whether execution logic disclosures meet regulator audit trail standards
  • U.S. Department of Justice scrutiny of algorithmic pricing coordination as a competition law trigger

Recent material activity in Technology, AI & Competition

  • Apr 11, 2026 MATERIAL

    NIST releases updated AI Risk Management Framework companion guide for critical infrastructure

    NIST published AI RMF 1.1 companion guidance specifically addressing AI deployment in critical infrastructure sectors including energy, financial services, and healthcare. The guide introduces mandatory risk assessment c…

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