Since 2021 a new regulatory focus in US financial services has seen JPMorgan Chase fined $200 million for recordkeeping violations via personal devices
Off-channel communications such as unapproved channels like text, social media used for business have come under increasing scrutiny
In total, the SEC and CFTC has settled more than $1.3 billion in 26+ cases for electronic communication and record-keeping failures
DOJ's focus on personal device messaging platforms for compliance risks.
Recent DOJ guidelines advise evaluating corporate governance regarding personal devices.
Lessons learned include adoption of approved communication methods policy, monitoring and archiving of permitted communication modes, staff training on policies and procedures, and documentation of non-compliance incidents and implement escalation and remediation systems
