Can a Single Employee Bypass a Digital Chinese Wall If They Have Multiple Roles?
Yes, a single employee with access to multiple roles that span the Chinese Wall (e.g. a developer with access to both the proprietary trading code and the matching engine data) presents a significant risk. This is why financial institutions enforce strict policies against dual-hatting and implement surveillance to monitor all activity associated with such privileged accounts, looking for correlations between data access and trading activity.
