It’s important for regulated firms to review the adequacy of digital communications policies and supervisory systems themselves. At a minimum, written supervisory procedures (WSPs) should outline:

• Names and titles of reviewers
• The process reviewers will follow to conduct each review
• Timing and frequency of review
• How the reviewers will evidence that the required supervisory steps were taken (including provisions for the escalation of regulatory issues to the designated supervisor or other appropriate departments)

WSPs should be updated not only to reflect regulatory changes but also when changes are made to the firm’s supervisory process. All firms should have regularly scheduled formal testing plans for all WSPs and their overall processes. Testing will ensure processes are being followed and any gaps are quickly identified and addressed. These strategies will help with timely supervisory control reviews and avoid the “set it and forget it” approach.

Reporting is another tool for ensuring an effective compliance program and lexicon maintenance. Reports are helpful tools to review the number of searches and audit history. They should provide a detailed history of how your lexicons interact with messages ingested in your archive. They can also help minimize false positives and unnecessary reviews which place a considerable burden on time and resources.

Regularly reviewing content reduces the need to examine giant swathes of data at wider intervals. It also increases the opportunity to identify problems early and often. Content review cycles should be weekly, but no less than once a month. We recommend performing a risk analysis to determine the frequency of your review cycles and the percentage of correspondence to surveil. And don’t forget to revisit these parameters as part of your annual review of the process.