Figure 1. Simplified Components of eCommunications and Voice Surveillance
Source: Opimas analysis
The most sophisticated surveillance programs at financial institutions rely on complex processes to record, store, analyze, and map trade-related activities across a variety of communications channels (Figure 1). While even the smallest outfits (mostly out of view of the regulators) typically store at least their email communications, the most advanced are also proactively watching employees’ activities across chat applications, fixed-line telephones, turrets, VoIP applications, mobile phones, social media, and an ever-growing number of other channels. Most, however, only monitor proactively in English or their native language (Figure 2).
When not in English or the native language, many compliance teams struggle to keep up with the task of monitoring their workforces’ verbal and text communications. The importance of crafting a thoughtful approach to monitoring the multiple languages in use at a financial institution cannot be understated. If ignored, the firm leaves itself blind to potentially damaging behavior, easily masked by the use of an unmonitored language or dialect. With over 6,000 languages worldwide, surveillance of only English and/or the native language is a risky choice.
Fines for market manipulation peaked in 2015 just shy of US$9bn. Since falling in 2016, they have increased again slightly, though not to their 2015 level. This is important in the context of communications surveillance, because the “failure to monitor communications” can be found in many of the market misconduct rulings that contribute to these fines.
In this report, Opimas emphasizes the importance of surveillance across languages, identifies current adoption rates, describes standard approaches used by market participants, and briefly introduces the solution providers that help compliance teams better manage the surveillance of their multilingual workforces.