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Electronic Communications Surveillance

For regulated companies to establish an effective supervisory system, it is critical to ensure that the internal and external communications of their supervised individuals are being adequately reviewed and properly retained. Regulators expect companies to have robust electronic communications surveillance processes that are tailored to their business, size, structure, and customers, among other attributes.

Treliant provides extensive electronic communications surveillance services—from ongoing programmatic reviews required by regulators to responsive event-driven analyses that address specific internal, external, or regulatory issues.

Our experienced surveillance team can assist firms by establishing and implementing protocols to effectively assess electronic communications, conducting thorough reviews targeted to each company’s needs and regulatory risk, and by enhancing procedures for testing, reporting, and documentation. Treliant’s Electronic Communications Surveillance and Review services help clients with the following:
 
Establishing and Implementing an Effective Surveillance Process 
  • Identifying various forms and sources of electronic communications for review
    • E-mail, instant messages, social media, blogs, Bloomberg messages, etc.
  • Reviewing efficacy of e-communications surveillance programs, including data leakage controls
  • Reviewing efficacy of lexicon-based surveillance systems focused on employee behaviors, client abuse, insider trading, market manipulation, and other forms of potential misconduct
    • Testing and reviewing lexicon-based components of surveillance programs
    • Identifying areas of lexicon enhancement
  • Working with archiving vendors to optimize surveillance and reports
  • Identifying and applying any regulatory developments and guidance pertinent to the review

Conducting Thorough, Preventative, and Responsive Reviews

  • Undertaking e-communications reviews to assist with regulatory reviews, internal investigative reviews, and other ad hoc reviews
  • Providing resources to address surveillance alert backlogs and other remediation efforts
  • Flagging and properly escalating communications of potential concern for further review
  • Identifying, refining, and proposing search terms and phrases
    • Focusing search terms and review on company’s specific business(es) and risk areas
    • Identifying password-protected attachments and image files for review
  • Reviewing electronic communications in conjunction with company policies and procedures
  • Providing the compliance team with a report on surveillance parameters and observations

Testing, Reporting, and Documentation

  • Reviewing and enhancing policies and procedures
    • Conducting gap analysis of electronic communications reviews and retention
    • Assessing effectiveness of company’s procedures for reviewing electronic communications
  • Establishing and enhancing processes for documenting communications reviews and findings
  • Educating and training employees on electronic communications policies and procedures

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