Do you Update your Email Flagging Keywords?
It is important to remember to periodically update your email flagging keywords if you use a monitoring system for electronic communications. Those systems, while powerful, are only as good as the dictionary of email flagging keywords used to call out a communication for review. Broker-dealers are required to supervise all communications relating to their investment banking or securities business, so says FINRA Rule 3110. Systems provided by Global Relay and SMARSH have the ability to call out electronic communications for review based on the parameters set by the system administrator. And a key element of an adequate supervisory system for reviewing communications is a robust set of email flagging keywords. Knowing the fine line about how much is too much is also important. Because a list that is too long and doesn’t use carefully thought-out lists of email flagging keywords will call out too many “false positives” for review, thus making the process ineffective.
To develop an effective list, consider conducting a thorough analysis of: 1) business lines and relevant keywords, 2) languages spoken by clients and employees, and 3) latest industry intelligence on terminology being used. It is important to understand that the manner in which we communicate, even in business, is constantly changing. For this reason, we must ensure that the supervisory systems and processes we use are updated in such a way as to remain relevant tools. The email flagging keywords list should be dynamic and should be the product of careful scrutiny and analysis.
FirstMark Regulatory Solutions is a broker-dealer and investment adviser compliance consulting firm based in Fort Lauderdale, Florida. FirstMark founder, Mitch Atkins, has written an article on LinkedIn, about email flagging keywords and some of the terms prosecutors and defense attorneys are using according to a September 2, 2015 article in Bloomberg Business. For more information or for help preparing your email flagging keyword list, contact Mitch Atkins at (561) 948-6511.