Regulatory Update: FCA Releases Findings from Recent Off-Channel Reviews

Overview of the FCA’s Multi-Firm Review

The Financial Conduct Authority (FCA) has released findings from its recent multi-firm review focused on off-channel communications. The review surveyed 11 firms, examining wholesale banking operations, asking for:

• The number of internal policy breaches over the past 12 months
• Details on policy enhancements implemented
• The Management Information (MI) used to monitor compliance

The FCA clarified that not all internal breaches were violations of FCA rules. It also emphasized that this was a “where-are-we-now” assessment—not an enforcement probe. Devices were not seized or interrogated, and the regulator relied solely on breach data provided by firms.

“All firms in our sample could evidence action taken to improve their approach, though to varying degrees,” the FCA noted. The FCA described the review as a ‘state-of-play exercise’ rather than a precursor to enforcement action.

Breach Statistics and Firm Accountability

Breaches Concentrated in Larger Firms

Eight of the 11 firms reported internal policy breaches, totaling 178 incidents. Of those, 131 breaches were concentrated in just three larger firms, suggesting uneven compliance efforts across the industry.

Senior Staff Still Falling Short

The FCA’s findings revealed that 67 breaches were committed by individuals at director grade or above. When including vice president-level staff, typically professionals with 8 to 10 years of experience, the number rises to 99. This points to a troubling trend: experienced professionals are still failing to meet compliance expectations. The FCA emphasized that individuals at these senior levels “should know better by now,” underscoring the need for stronger accountability among experienced staff.

Industry Culture and Compliance Challenges

Despite the existence of clear rules such as SYSC 10A, years of regulatory guidance (including MW66, published in January 2021) and billions in fines from global regulators, the industry continues to struggle with off-channel communication compliance.

The FCA’s findings suggest that too many individuals either believe they can avoid detection, consider themselves above the law or are simply careless in how they conduct professional communications. The review reinforces that compliance is an ongoing effort, with no finish line—firms must remain vigilant and proactive.

How ComplianceCentral Can Help

End-to-End Surveillance and Archiving

NICE Actimize’s ComplianceCentral platform offers a comprehensive solution for capturing, archiving and surveilling regulated employee communications and trading activity. It helps firms shine a spotlight on misconduct by unifying communication and trade surveillance into a single, cloud-based platform.

Addressing Off-Channel Risks

With the ability to monitor communications across platforms like Microsoft Teams, Zoom, WhatsApp and Bloomberg Chat, ComplianceCentral ensures firms are not blindsided by off-channel risks. It empowers compliance teams to detect hidden conduct issues and meet global regulatory expectations.

Build a Culture of Compliance

By leveraging advanced analytics and behavioral insights, ComplianceCentral helps firms foster a culture of accountability and transparency. It’s designed to support both proactive monitoring and responsive investigations, reducing the risk of costly fines and reputational damage.

Ready to strengthen your compliance posture? Explore ComplianceCentral and see how NICE Actimize can help your firm know more and risk less.

Access the Full FCA Report

The full FCA report is available on the regulator’s website.