Integrated Archive Supervision
For many years, financial services regulators have required enterprises to implement and monitor employee activity to proactively identify potential wrongdoing. Depending on the regions in which you operate, you will need to comply with one [or many] of the following regulators: the SEC, FINRA, IIROC, or MiFID II. Performing supervision has become increasingly difficult and complex due to the explosion of data.
Since the dawn of the Information Age, enterprises have adopted a number of new communication platforms to improve collaboration. While these platforms are aimed at improving business productivity, IT and compliance teams must archive and supervise all of this communication data in accordance with the aforementioned regulatory bodies.
In October 2019, FINRA released its “2019 Report on Examination Findings and Observations.” The report is intended to provide broker-dealers with key findings and observations identified in FINRA’s recent examinations. While the primary purpose of the report is to describe best practices that FINRA deemed to be effective to help firms improve their compliance and risk management programs, the report also highlights areas where they feel there is an area for improvement. Supervision was highlighted, see the excerpt below from the report [the full report can be found here: https://www.finra.org/rules-guidance/guidance/reports/2019-report-exam-findings-and-observations/supervision
“Insufficient Supervision for Specific Types of Accounts – FINRA noted the following supervisory issues.
Restricted and Insider Accounts – Some firms failed to update timely their watch and restricted lists, or reasonably identify and restrict account activity susceptible to insider trading. Other firms did not have surveillance systems or procedures to review and approve restricted trading because they relied on clearing firms to conduct the review. Both introducing and correspondent firms are required to have supervisory systems reasonably designed to detect and prevent insider trading.”
EAS delivers a unified archive platform to provide a single source of truth for compliance teams to demonstrate they are meeting the books and records requirements for long term archival as well as the ongoing supervision requirements.
--- Mike McGrath, UGA COO
This, of course, is driven by our core principle, a centralized platform for enterprise data archival. In the absence of a centralized archive repository, performing supervision is extremely difficult. EAS makes supervising corporate data easy, delivering compliance teams automated record keeping and supervision policy enforcement. This, in turn, enables compliance teams to spend their time investigating and remediating potential violations before they make front-page news.
Empower Your Compliance Officers
Consistent with EAS archive policies, EAS Supervisor delivers a powerful policy engine driven by lexicons to your compliance team. Depending on your use case, supervision may not be required for all employees within your enterprise, therefore EAS Supervisor provides a simple mechanism for compliance teams to group employees into risk-defined groups from Active Directory. Policies can be further configured to address the amount and type of sampling to be performed, custom workflows for escalation procedures, as well as alerts. Once messages are added to a reviewer’s queue, they can begin an investigation on flagged content.
EAS Supervisor provides a rich yet simple case management workflow to containerize the review process and enable compliance teams to collaborate on investigations. Furthermore, a powerful search component enables compliance team members to further investigate a custodian’s mailbox for content on a specific matter.
--- Joe Kreuz, UGA SAM
Risk Management and HR
While financial services firms have been mandated to perform supervision, it can benefit companies within any vertical in proactive risk management and corporate policy adherence. Implementing a supervisory program can help your teams identify potential legal matters proactively. Furthermore, although enterprises make their best efforts, from time to time bad actors will violate acceptable use and other corporate standards and ethics. This could be the sharing of trade secrets or a MeToo infraction. EAS Supervisor provides Risk Management and HR teams with the means to stop unwanted behavior before its too late.