Challenge
- Throughout the ten years of service operation, the customer underwent several adjustments in policies, processes and approach to meet the requirements of changes to laws/regulations, geopolitical developments, and growing regulatory scrutiny
- In 2021, following a series of high-profile investigations into the use of off-channel communications (e.g. social media comms and unrecorded lines), the SEC published guidance on the required approach to books and records keeping
- This was a significant expansion of focus for financial institutions, increasing both the volume of data and the level of scrutiny required
- This was compounded by the growing need for monitoring in local languages across all regions
- To remain compliant with the guidance, the company needed to maintain its current core processes while rapidly increasing its language capability and off-channel review expertise
Solution
- Expansion of our existing team, increasing our language capabilities in Hindi, French, Italian, Spanish, Japanese and German
- Intensive training on off-channel policy across all team members
- Targeted activities for the expanded team included
- Creation/implementation of additional review processes to address new areas arising from regulatory changes, focussed on high-risk individuals and topics
- Additional QC and governance processes, providing specific oversight of escalated cases throughout their lifecycle, and ensuring prompt resolution and accurate reporting
- First and second-line review of all communication types (chats, emails, audio)
- Initial investigation and diligence checks
- Escalation of potential violations, including providing any supporting evidence (such as other relevant communications, database checks, translations) as needed
