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New Supervision Lexicon for Encrypted Messaging Platforms

January 10, 2018

17a-4 has a new lexicon for encrypted platforms.  Terms and phrases associated with encrypted messaging platforms have been curated by 17a-4’s Compliance Services team and are now available for clients.    

Millbrook, NY – 17a-4’s new Encrypted Platform Lexicon provides a list of terms and phrases for financial compliance teams to easily discover if employees are using or planning to use platforms such as Telegram, Signal, Confide and WhatsApp.  This lexicon may be incorporated with other supervisory lexicons to provide a comprehensive base for FINRA Rule 3110 compliance.

Platforms such as Telegram, Signal and WhatsApp are encrypted platforms which are virtually impossible for financial institutions to archive and properly supervise as required by FINRA Rule 3110 (broker/dealers) and SEC rule 206(4)-7 (registered investment advisors).  The lexicon will flag for review messages which indicate that an employee uses or tries to use one of these platforms.  As firms now bring all types of messaging – text messaging, Bloomberg, Symphony, Skype or Cisco Jabber – into a consolidated archive, the lexicon will search across these platforms for evidence of use.  For instance, if a trader on Bloomberg tells another trader that he wants to switch the discussion to Telegram, that message would be flagged for compliance review. The lexicon can be used to catch these conversations and allow a compliance officer to proactively reach out to these employees to make sure they understand the institutional policy relating to these platforms.

“As part of FINRA’s exam,” says Douglas Weeden, Director of Compliance and e-Discovery, “institutional lexicons are reviewed to ensure they’re relevant to the type of business conducted by the institution and reasonably designed to find illegal or inappropriate activities.  As these encrypted platforms are now widely used, we encourage firms to include such directed terms and phrases that alert compliance officers to the use of non-approved communication platforms.”

Availability of the Encrypted Platform Lexicon

The new lexicon is available at no cost to 17a-4’s Designated 3rd Party clients (Rule 17a-4) and those who subscribe to 17a-4’s Lexicon Update Service.