Measuring the effectiveness of a communications compliance program

January 23, 2026by Robert Cruz

Subscribe to the Smarsh Blog Digest

Subscribe to receive a monthly digest of articles exploring regulatory updates, news, trends and best practices in electronic communications capture and archiving.

Smarsh handles information you submit to Smarsh in accordance with its Privacy Policy. By clicking "submit", you consent to Smarsh processing your information and storing it in accordance with the Privacy Policy and agree to receive communications from Smarsh and its third-party partners regarding products and services that may be of interest to you. You may withdraw your consent at any time by emailing [email protected].

TL;DR: A strong communications compliance program reduces regulatory risk and protects your firm. Use a structured maturity model and self-assessment framework to identify gaps, prioritize investments, and leverage AI for continuous improvement.

Determining the effectiveness of a communications compliance program is not a new concept in financial services. Adjusting the mix of technologies, policies, and training investments can be done the easy way or the hard way. The easier — but often more painful — approach focuses on fixing bad outcomes such as regulatory actions, client loss, or other consequences resulting from under-managed information risk.

The harder approach is determining which investments move the needle the farthest, advancing programs from deficient to operational to best-in-class. Complicating this task is the fact that the environment is dynamic, reflecting ever-evolving AI capabilities being leveraged not only in the risk and compliance office but across the organization in support of hundreds of AI use cases.

The fundamental challenge of finding risk-bearing needles in communications haystacks now must also account for agent-generated needles in synthetic haystacks.

How firms identify their current compliance maturity

The key question is: how does a firm identify its current state to prioritize investments that improve risk management effectiveness?

We’ve worked with hundreds of firms on this journey and have consolidated those learnings into a communications intelligence maturity model that firms can use to self-assess where they are today and prioritize goals for improvement.

Communications intelligence maturity model: the five levels

The maturity model (MM) outlines five levels of maturity:

Level 1: Deficient
Characterized by compliance coverage gaps and an inability to satisfy regulatory expectations.

Level 2: Developing
Meets basic regulatory obligations, but coverage gaps remain and unidentified communications risks continue to be a concern.

Level 3: Operational
Risk coverage is complete through operationalized controls, but inefficiencies remain high, with compliance teams focusing on false positives rather than true risks.

Level 4: Advanced
Demonstrates the ability to surface and remediate the most impactful risks across most communications sources.

Level 5: Best-in-class
Operates with a proactive posture to detect true risk across languages, channels, and populations through advanced AI-driven techniques.

Self-assessment dimensions for compliance officers

Each level is explored in self-assessments tailored to specific functions. For compliance officers, the dimensions include:

Communications compliance program
Focuses on overall program effectiveness, the ability to meet regulatory expectations, and maturity in operationalizing policies, practices, and training programs (25 possible points).

Communications capture management
Examines how risk-bearing data is consumed, where compliance gaps may exist, and how approaches to communications capture are managed as capabilities, features, and vendors evolve (35 possible points).

Information storage management
Assesses the extent to which information is retained to meet regulatory obligations across business areas, geographies, and languages, as well as how flexible facilities are in enabling granular policies and regional mandates (40 possible points).

Surveillance and oversight
Evaluates objectives for first and second lines of defense, coverage across sources leveraged by the business, and methods used to identify and mitigate risk (50 possible points).

Interpreting maturity model scores

Scores for each dimension are tallied and interpreted as follows:

30–75 points: Developing program
Indicates basic controls exist but confidence in regulatory outcomes is limited. Firms may have persistent compliance gaps that could attract greater regulatory scrutiny.

76–125 points: Advanced program
Shows success in identifying and remediating true risks, with potential to scale supervision and extend controls beyond regulatory expectations.

126–150 points: Best-in-class program
Reflects a proactive posture and effectiveness in spotting the most impactful risks. Firms can advance AI-driven risk intelligence, optimize risk spending, and position compliance as a strategic asset.

Expanding self-assessments across functions

Unique self-assessments can be developed for technology and legal stakeholders, with dimensions and questions tailored to each function. While many responses are qualitative, multiple stakeholder perspectives foster discussion, help align priorities, and allow progress to be monitored over time, backed by quantitative measurement.

Practical takeaway: compliance is a journey, not a destination

Improving the effectiveness and maturity of a communications compliance program is an ongoing journey. Changes in communications technologies, regulatory priorities, and AI-driven tools will continually test the limits of existing compliance controls.

Assessing where you are on this journey not only reduces the risk of negative outcomes but also provides a path toward proactive risk management and continuous innovation.

Share this post!

Robert Cruz
Smarsh Blog

Our internal subject matter experts and our network of external industry experts are featured with insights into the technology and industry trends that affect your electronic communications compliance initiatives. Sign up to benefit from their deep understanding, tips and best practices regarding how your company can manage compliance risk while unlocking the business value of your communications data.

Ready to enable compliant productivity?

Join the 6,500+ customers using Smarsh to drive their business forward.

Contact Us

Tell us about yourself, and we’ll be in touch right away.

icon-angle icon-bars icon-times