When the coronavirus pandemic forced governments around the world to impose lockdowns, businesses scrambled to adapt almost overnight.
With business continuity plans kicking in, the shift to remote working invariably meant a significant increase in electronic communications for compliance officers to monitor.
Covid-19 quickly underscored the importance of not only having a robust business continuity plan in place, but also having well-crafted and up-to-date supervision policies to ensure compliance teams are capturing the right data without being swamped by unwanted noise.
One business that has done well on both of those fronts is global asset management firm Amundi Pioneer. Agnes Filocha, deputy chief compliance officer at Amundi Pioneer Distributor, Inc. participated in our recent webinar on how to build and manage policies that will withstand the rigors of a pandemic and the challenges of remote working.
The main reason Amundi Pioneer was able to adapt swiftly to remote working was because it had prepared meticulously. In addition to regularly stress-testing the impact of working from home as part of its regular business continuity planning, Filocha and her compliance team had worked with Global Relay to ensure its eComms supervision tools were properly configured.
“Something that was especially useful for us was the policy calculate feature,” said Filocha, referring to the ability to test how many messages a policy matches against, on a given date. “It really helped us adjust our lexicons to be smarter about what we were trying to have the system do for us. The search results that we were going to get back were so much better than just blindly adding new terms into the lexicon that you think might work, but you’re not quite sure.”
Whitelisting email addresses in real time has also helped prevent the firm’s compliance reviewers from being inundated with junk emails, allowing them to focus on the messages that matter.
“We’re adding junk email into the whitelist instantly—why wait and just have that fill up your system? It’s amazing how much time it saves both reviewers and the firm if you set that up on a live basis,” she said.
While Amundi Pioneer was well prepared, the adjustment to remote working over an extended period of time—as opposed to the one or two days the firm had tested for in its remote working drills—meant it did encounter some new challenges. One of those was the increased reliance on collaboration platforms. Amundi Pioneer already had one long-time video conferencing partner, but the firm realized there was a risk to relying on just one provider, if its platform were to go down.
The firm also realized that selecting a robust backup system needed input from the compliance team in order to avoid potential retention issues later on.
“We frequently reach out to Global Relay and ask for their advice to understand what they are seeing in the industry, just to help guide us, because you really don’t want to walk into a record keeping issue if your firm decides to roll out a new communication platform that isn’t supported from a retention and monitoring perspective—you don’t want to go down a path too far and realize you can’t go back,” she said.
Lessons to Learn
Taking the time to set up smart supervision policies and email whitelisting really paid dividends for Amundi Pioneer’s transition to remote working. By getting the policies right Amundi Pioneer was able to reduce the number of false positives being flagged, making it easier for the firm’s reviewers to keep focused on messages requiring scrutiny, amid a significant increase in message volumes.
Keeping an eye on message volumes is also essential. While Amundi Pioneer’s volumes increased, as expected, Filocha said if a firm’s volumes haven’t increased it doesn’t necessarily mean something is wrong. If there was a reduction in employee numbers because of furlough programs or redundancies, and message volumes remained steady, that would still add up. But if the workforce stayed the same and volumes decreased, that would be something to investigate, she said.
“It might be people switching to unapproved communication channels, so more training may be needed, or maybe the policy needs to be put in place so you can monitor for that and ensure that’s not happening,” Filocha said.