E-comms Surveillance
Maximising your firm’s time and efficiency with streamlined centralised surveillance solutions.
SERVICESService Overview
- What is the
client issue? -
Regulators globally have an expectation for financial services firms to conduct monitoring surveillance of employee electronic communications. The requirements vary from strict rules on the SEC side to risk-based approach focused on regulatory outcomes on the FCA side. Irrespective of which regulatory regime your firm falls under, some level of electronic communications monitoring must be completed by your Compliance team. This can be very manual and time consuming, not to mention inefficient if you do not have a targeted, risk-based surveillance programme in place.
- How does
Optima help? -
Our clients depend on our trained, dedicated global team to conduct electronic communications surveillance on a weekly, monthly or quarterly basis, in line with our clients’ monitoring programme. Given our breadth of expertise, interaction with regulators and broad client base, we are continually updating the surveillance lexicon and surveillance methodology to be in line with regulatory expectations.
Our global team has vast experience of working with and using third-party surveillance tools, such as Global Relay, Bloomberg Vault and Mimecast, to name a few that we see our clients utilise.
Our all-encompassing service includes:
- Design of a risk-based electronic communications surveillance framework, which includes design of a tailored surveillance lexicon that is relevant to your business and compliance risk.
- Surveillance plan which sets out frequency of monitoring and sample sizing, as well as employee selection, where relevant.
- For firms subject to MiFID II, our surveillance programme also includes telephone recording monitoring, based on a risk-based approach and target employee surveillance who are subject to MiFID II telephone recording requirements.
- Issuance of monitoring reports, documenting findings, issues and recommendations.
- Trend analysis to update your surveillance framework, sampling methodology and surveillance lexicon on an at least annual basis.
Electronic communications & telephone recording monitoring
We were engaged by a global asset manager to conduct electronic communications surveillance for both their UK, US and Hong Kong regulated entities. The client utilises Global Relay for the storage of all electronic communications.
In addition, our mandate included monitoring of recorded telephone conversations of the UK office.
As part of the engagement scope, we conducted a risk assessment of each office to design and implement the surveillance framework for each jurisdiction. In the US, all employees were subject to electronic communications surveillance based on a single surveillance lexicon.
However, in the UK different policies and different surveillance lexica were implemented for various teams to target the specific FCA risk areas, such as market abuse (for the trading teams) and mis-selling (for the marketing teams).
In addition, a risk-based approach and sampling methodology was implemented for the telephone recording surveillance, which was targeted for the trading teams only during specific research and deal periods of the client’s activities.
Optima has been successfully supporting this client with outsourced electronic communications and telephone recording surveillance for the last 24 months and continues to deliver timely and comprehensive reports to the client on a quarterly basis.
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