To do it right, all details of the case should be accessible at any given time. Let’s dive into the “accessible” component a little further.
Typically, this is how it goes. Someone monitoring emails or transactions observes something aberrant. They start to look a little deeper (hence “deep-dive case management”) and a few more things look out of the ordinary. It might be as simple as who’s texting with whom or the oddly coincidental timing of a vague text and particular trades.
To begin the investigation, the compliance officer needs to request access to all previous communications of a particular employee. Yes – this is painful. Awaiting approval can take days. And that assumes that the IT person tasked with facilitating your request isn’t already backlogged on a zillion other requests. At some point thereafter, you’ll receive the dreaded note from the IT person that says something like, “The past communications that you requested have been archived on tape. Our current solution replaced our legacy compliance solution, and accessing that data on tape isn’t a straightforward process. It’s going to take days, most likely weeks until we get to it.”
By the time that the IT person re-activates a legacy in-house algorithm to access the data on the tapes which are archived in the depths of some basement, the suspected market abuser has already made millions of dollars, set up an account in the Cayman Islands, and gone off the grid.
Well, maybe not exactly, but that scenario is not as crazy as it sounds. Deep-dive case management means that you’re in control of all the data (yes, including what was archived a long time ago), people, policies, and whatever else that you need to present the authorities with the “full story.” In the absence of that, you don’t really have a case management solution at all.