Not all surveillance systems are created equal

Not all surveillance systems are created equal

One size does not fit all when it comes to channels

Over the past year and a half, financial services firms have broadened their footprints with respect to communications media. But as referenced in a recent survey, they typically haven’t dedicated new resources to support that effort. As electronic communications surveillance programs continue to be challenged with increased responsibilities and decreasing resources, compliance teams may prioritize consistency and efficiency in an effort to standardize their approach to different types of communications.

Unfortunately, at Hearsay, we’ve seen that this approach may result in suboptimal implementations of lexicons across surveillance platforms. Different platforms are used for different reasons. Emails and text messages, considered “Electronic Communications” under the applicable rules, inherently contain different language: Emails tend to be more formal and longer, while text messages are impromptu and more colloquial. For its part, social media is itself a separate type of messaging subject to similar, yet different different rules and frameworks.  

As each of these communication channels present unique risks in specialized contexts, applying a one-size-fits-all approach for consistency is an imperfect risk mitigation method. For example, the Marketing Rule, with which firms must comply next year, requires special consideration for testimonials and endorsements. Firms that fail to include this context in their social media lexicon could find themselves out of compliance with the Marketing Rule. 

How Hearsay’s flexible lexicons help manage channel-specific risk

Hearsay identifies channel-specific risks by detecting different terms across various activities and channels. For example, Hearsay recognizes that private messaging presents different risks than outbound publishing activities, and can customize lexicons to identify risks in those specific communication channels. This enables Compliance teams to identify the communications that are most relevant to them, increasing efficiency through a measured approach.

When considering your lexicon—either during an annual review of your lexicon’s effectiveness, or when implementing a lexicon for the first time—ensure that you account for how each communication channel you’re monitoring is being used. Although firms seek consistency with respect to the risks they’re required to identify, unless they embrace a contextual approach to the various communication platforms, they’re unlikely to fully account for those risks with just one lexicon across all monitored platforms.  

To discuss how to implement a more flexible application of your organization’s lexicon, and how it can be optimized to surveille for unique channel-specific risks, don’t hesitate to reach out to Hearsay’s Compliance team, who can walk you through best practices for lexicon management.

Bill Simpson
By day, Bill Simpson is Hearsay’s Senior Compliance Manager, helping deliver technologically compliant solutions to Hearsay’s global customer base. Once he logs off (or sometimes before he logs on!), he can be found tending to his BBQ pit, playing with his two boys, or enjoying collaborative storytelling via tabletop RPGs.

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