Client Profile:
Full-scope AIFM with MiFID top-up permissions | 3-person compliance team | FCA regulated
The firm had onboarded a recorded communications system but lacked the internal resource to integrate this appropriately, create a governance framework, and technical configuration expertise to implement it effectively within the approved budget.
Client Challenge:
- 300–500 alerts per day (~7-10% of all daily ingested communications)
- High alert fatigue leading to missed true positives
- No procedure for triage, governance, audit trail, or Board reporting
- Low level of integration due to already over-stretched demands on the team with just email communications integration
- Lean team unable to remediate system or design procedures
Solution Delivered:
10 Days – Hybrid Operating Model
Regulatory and governance
- Recorded Communications Risk Assessment
- New Recorded Communications Policy + Supervision and Triage Procedure
- Governance documentation + Board reporting templates generated in the system
Technical & operational remediation
- Lexicon tuning (reducing unnecessary triggers)
- Integration uplift across channels
- Workflow redesign for triage, escalation and auditability
- Review process rationalised
Collaboration
- Close work with vendor to diagnose alert logic and work to understand the system methodology
- Embedded model with internal team, including provision of training to internal team
Impact:
Quantitative
- Alert volumes reduced from ~10% → ~0.5-1.0% using statistical modelling
- review burden reduced from 2.5 days/week → 0.5 days/week with appropriate risk-based procedures
- Positive identification improved significantly
Qualitative
- System now fit for regulatory purpose
- Governance framework suitable for FCA
- Board can have visibility and assurance
- Internal team equipped for effective BAU
Why the hybrid operating model worked:
- Internal team maintained BAU ownership
- External SME delivered deep domain/technical expertise rapidly
- Far faster and more cost-efficient than alternative resourcing
- Sustainable long-term outcome with robust documentation