Electronic communications surveillance that closes every alert with a written reason and checks every off-channel move for a record
Every alert closed with a written reason, every off-channel move checked for a record.
See one case, screen by screen ↓Electronic communications surveillance is the review of a firm's emails, chats, mobile messages and recorded calls for risks such as inside information, off-channel moves, collusion and complaints, with evidence of each review. As communications surveillance software, Electronic Communications Surveillance adds seven agents that rebuild each flagged conversation across channels, put English beside the original, check every off-channel move for a recorded follow-up and propose a disposition with a written, cited reason — a reviewer decides and a supervisor countersigns every escalation.
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Electronic communications surveillance at a global manager starts with millions of emails, dealer chats, Teams messages, mobile messages and recorded calls a month. Lexicons in a dozen languages flag tens of thousands of them, and more than nine in ten flags are noise: research footers, market color quoting public news, out-of-office replies. Reviewers clear them one message at a time, without the rest of the conversation from the other channels, and often in a language they cannot read — the Portuguese line goes to a translation tool in another window, or waits for the one colleague who reads it.
The real risk waits in the same five-day queue. A trader's "call me on my cell, not here" looks like every other off-channel phrase hit, and it is usually closed because nobody checks whether a recorded call followed. Most alerts close with a pick-list code and no written reason, although FINRA Rule 3110 asks for review evidenced in writing that names the reviewer, the message and the date — merely opening a message is not a review. The SEC's off-channel recordkeeping sweep showed the price of getting this wrong.
Estimated split for one multilingual alert that ends in an escalation, by hand and with the solution.
Seven agents rebuild, translate, classify and check every flagged conversation; reviewers decide, supervisors countersign.
Quillfield Capital runs about $900 billion from New York, London and Singapore and monitors 2,140 people. On Wednesday, October 14, the Portuguese off-channel lexicon flagged a dealer chat on the EM debt desk in New York. Here is what happens next, screen by screen, in the working solution.
Overnight the agents read 148,920 new communications and grouped 1,402 flagged messages into 486 new alerts. Priya's home screen shows 1,284 open alerts, 1,071 proposed to close with a reason, 3 escalations for her countersign and 41 alerts near the 5-day review deadline. Below them, one next step each: a rule change to approve, 3 QA reopens and a Singapore mobile feed running 2 h 10 min behind, its review clocks paused.
Risk agent: “One matters most: a Brazil desk chat where a trader moved a broker's call to his cell phone. No recorded call followed, and he sold USD 12.5 million of the bonds 23 minutes later.”
Priya types to the agents the way she would to her team: “Assign Portuguese alerts to Marta.” The agents move 38 open Portuguese alerts to Marta Kowalczyk, who reads Portuguese natively, and record the instruction under Priya's name on the audit trail. She can also ask what QA reopened or which alerts are near the deadline.
“Done: 38 open Portuguese alerts are now assigned to Marta Kowalczyk. Logged as your instruction.”
Alert ECS-2026-104417 opens as one thread: 9 items across 5 channels — email, dealer chat, Teams, the call record and the order. Tiago Albuquerque of Serra Alta Securities writes that a deal “ainda não é pública” — is not public yet — then gives the size and timing of the Andorinha reopening. Rafael Monteiro replies “Me liga no celular, não aqui.” Down the left, the risk gutter marks each line: inside information at 0.81, off-channel at 0.94. A strip above shows his 3 prior alerts, his attestation signed Jan 12 and his enrolled phone.
“Originals are the record; English is the Language agent's reading beside them. Every row cites its archive record.”
The Thread agent searched every channel for Rafael Monteiro and Tiago Albuquerque from October 12 to 16 and kept only the items about Andorinha Energia or the call. The other 31 — a lunch order, a LatAm credit newsletter, a settlement confirmation — are listed with why they were left out: no issuer, order or call in common. Each one is still in the archive.
The Thread agent never removes a message from the record; it only orders and groups.
The Off-channel agent searched the turret recorder, the mobile capture and the approved messaging apps from 9:44 a.m. to noon. Turret line NY-EMD-14 recorded 23 calls that day, none with Serra Alta's numbers; enrolled phone QF-MOB-2231 has no calls or messages with Tiago Albuquerque; approved apps, none. At 10:06 a.m. the order system shows Rafael selling USD 12,500,000 Andorinha Energia 6.250% notes due 2034 at 98.40 — 23 minutes after the chat.
“Result: no recorded follow-up to the 9:43 a.m. request.” A personal phone is outside what the agent can see.
Priya asks the agents what “me liga no celular” means. The Language agent answers: informal Brazilian Portuguese for “call me”, on my cell phone, not here — a request to move off the recorded channel — with the source line cited and a confidence of 0.97. She could also ask whether Rafael has done this before, or have the Case agent draft a question for Legal.
Language agent: “Together: call me on my cell, not on this chat — a request to move off the recorded channel. Confidence 0.97.”
Marta Kowalczyk agreed with the agents and escalated the alert on Monday at 8:52 a.m. with reason codes OC-02 and MN-01 — moved to an unrecorded line, non-public deal information received. Priya ticks the next steps: open recordkeeping review RKR-2026-019, send case CASE-2026-0131 to Samuel Achebe in Legal, refer the October 14 sale to trade surveillance and propose Andorinha Energia for the watch list, which the Control Room decides. Her written reason is kept as evidence of review.
“Your countersign sends it on; the agents carry out only the steps you tick.”
The queue groups what the agents propose to close by reason: 412 newsletter and research footers, 236 market color messages quoting public news, 164 off-channel phrases with a recorded follow-up found, 141 automated messages, 118 personal or social. In the batch, every alert carries its own written reason, whatever its language — English, German, Japanese, French. Marta sends back any alert whose body has risk, ticks that she reviewed the agents' reasons, and approves the rest.
“I reviewed the agents' reasons for these 412 alerts.” Her name, the date and the reason go on every close.
Since October 1 the Off-channel agent has found 2,206 moves to another channel in 12 languages. 2,171 matched a recorded follow-up within 30 minutes, with the record cited; 35 had none, and each one is in front of a person. Rafael's alert now sits in the recordkeeping reviews as RKR-2026-019, beside six others with an owner and next step. The Q3 attestation shows 2,131 of 2,140 people signed, with one click to remind the 9.
“The absence of a record is evidence too.”
Each month the QA agent re-reads 5% of closed alerts blind. In September it re-read 489 of 9,772 closes, agreed with 482 and reopened 7 — a German “the numbers only come out Thursday, but they are good” among them — for a different reviewer to decide. The Case agent drafts the monthly surveillance report with every number tied to its alerts: 9,860 alerts, 88 escalated and countersigned, 14 sent to Legal, median 1.6 days to a decision. Catherine Doyle signs it.
“A different reviewer decides; the original closer cannot.”
The same flagged conversation, seen by five of the people who carry it — what their week looked like, and what it looks like now.
Seven agents rebuild, translate, classify and check every flagged conversation; reviewers decide, supervisors countersign.
Pulls every email, chat, mobile message and recorded call from the archives, resolves people against the HR directory, detects the language and watches feed health — 7 sources and 2,140 monitored people at Quillfield.
Rebuilds the conversation around a flagged phrase across every channel — same people, same issuer, ±48 hours — with the related order, and lists what it left out and why.
Puts English beside every original message in 12 languages, with idiom notes for desk slang and a confidence score.
Classifies the risk of each message against the firm's policies, links orders in the window, checks the wall-crossing register and the watch list, and proposes a disposition with reason codes and a written reason.
Checks every “call me”, “text me” or “move to another app” against the turret recorder, the mobile capture and the approved apps, and shows the recorded follow-up — or every system it searched when there is none.
Re-reads 5% of closed alerts blind each month, at least 2 per reviewer and language, reopens any it disagrees with and reports reviewer agreement.
Drafts the escalation memo, the evidence for Legal, the monthly surveillance report and the export for an exam request.
Close, countersign, decide, sign. The agents propose; a named person decides.
Ask about any alert, person, rule or report in plain words — or give an instruction. Every answer cites its source, and what the agents may not do, they say.
Which escalations need my countersign today?
Three, all reviewed and agreed by a reviewer: ECS-2026-104417 — Brazil desk, deal details from Serra Alta Securities, call moved to a cell phone, no recorded call, a USD 12.5 million sale 23 minutes later, made by Marta Kowalczyk; ECS-2026-104380 — Singapore, unpublished quarterly figures from an issuer contact, in Mandarin, made by Hui Min Goh; ECS-2026-104371 — Wealth, a written complaint about an unauthorized sale, in Spanish.
How many off-channel moves had no recorded call this month?
35 of 2,206 moves found since October 1 had no recorded follow-up; 2,171 matched a recorded call or an approved app within 30 minutes. Of the 35, 6 are open recordkeeping reviews, 5 are in the queue now, and 24 were closed by a reviewer with context, for example a recorded client call on another line.
What does 'me liga no celular' mean?
“Me liga” is informal Brazilian Portuguese for “call me” (from ligar, to phone); “no celular” is “on my cell phone”; “não aqui” is “not here”. Together: call me on my cell, not on this chat — a request to move off the recorded channel. Confidence 0.97.
Approve the research-footer suppression
I can't approve rule changes — that is your decision as the checker. Ravi Menon submitted Exclusions and suppressions v15 on Oct 18. Back-test on September: 1,140 fewer alerts (9,860 → 8,720), 0 of 88 escalations missed, 0 QA reopens affected. I have opened the change so you can approve it with a reason.
13 screens from the working solution, on its sample data. Pick one to see it large.
Deadlines, thresholds and sampling are settings. A change is saved as a pending version, and the Chief Compliance Officer approves threshold changes.
| Setting | Default | Choose from |
|---|---|---|
| Review deadline | 5 business days from the alert | Set in business days · FINRA 3110 timeliness and firm policy |
| Auto-escalate at the deadline | On | On or off · goes to the person's supervisor |
| Countersign an escalation within | 1 business day | Set in business days |
| Agents may propose a close at confidence | 0.90 or higher | Below the threshold, the alert goes to “Needs judgment” |
| Send to a native-language reviewer below | 0.80 | Language agent confidence per message |
| QA re-sample | 5% of closed alerts each month | Percent of closes · at least 2 per reviewer and language |
| Off-channel match window | 30 minutes after the move | Minutes searched for a recorded follow-up |
| Reason codes | FP-01…06 false positive · CN-01…04 coaching · OC-01…04 off-channel · MN-01…03 inside information · CO-01 collusion · CM-01 complaint · GE-01 gifts | Edit codes, under the same approval |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC off-channel sweep since December 2021 — more than 100 firms and over $2.2 billion, SEC and IQ-EQ; SEC press release 2024-144, September 24, 2024 — $88.2 million across 12 firms; FINRA Rule 3110(b)(4) and Supplementary Material .07 on evidence of review). Quillfield Capital and the people, companies, instruments and figures named on this page are fictional — characters and sample data in the working solution.
Electronic communications surveillance is the review of a firm's emails, chats, mobile messages and recorded calls for risks such as inside information, off-channel moves, collusion and complaints, with evidence of each review. As communications surveillance software, Electronic Communications Surveillance adds seven agents that rebuild each flagged conversation across channels, put English beside the original, check every off-channel move for a recorded follow-up and propose a disposition with a written, cited reason — a reviewer decides and a supervisor countersigns every escalation.
The agents propose closing noise — research footers, market color quoting public news, automated messages — in batches grouped by reason, each alert with its own written reason, and a reviewer approves or sends back every one. Below 0.90 confidence an alert goes to a person. The QA agent then re-reads 5% of closes blind, and a lexicon change that would cut alerts is back-tested on last month before the Head of Surveillance approves it: on the sample data, 1,140 fewer alerts with 0 of 88 escalations missed.
For off-channel communications compliance, the Off-channel agent takes every “call me”, “text me” or “WhatsApp me”, in any of 12 languages, and searches the turret recorder, mobile capture, approved apps and calendar for a follow-up between the same people within 30 minutes. A match is cited and the alert can close; with no match, every system searched is listed and a person decides, with a supervisor countersigning. Where no record exists, a recordkeeping review follows the move up.
Every close and escalation carries a reason code, a written reason, the reviewer's name and the date and time, linked to the message reviewed. FINRA Rule 3110 Supplementary Material .07 says reviews must be evidenced in writing and that merely opening a communication is not a review. The audit trail and the exam export carry the same record.
Yes. The Language agent keeps the original as the record and puts English beside every message in 12 languages, with idiom notes for desk slang and a confidence per message. Below 0.80 confidence it routes the message to a native-language reviewer, and a reviewer can ask what a phrase means and get a cited answer.
It reads the turret voice recorder's transcripts and mobile call recordings, and approved messaging apps and SMS on enrolled phones, alongside email, dealer chat and Teams. Calls are part of the rebuilt conversation and of every off-channel check. A personal phone is outside the archive; when a move has no record, the review asks the person to preserve and produce messages, and Legal decides how.
Yes. The agents propose and never close, escalate or contact anyone. Reviewers decide every alert, a different supervisor countersigns every escalation, a different reviewer decides each QA reopen, Legal sees escalated cases only and decides outcomes, and rule and threshold changes wait for approval.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your policies, lexicons, reason codes and archives — and it goes live once every quality gate has passed. In the working solution, first-time setup is six steps, from connected archives to a program back-tested on last month. We will walk you through it on your own flagged messages first.
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1-min demoWe'll run Electronic Communications Surveillance on a sample of your own flagged messages and the archives they come from.