Regulatory Alerts2020-03-23
Added · Updated
Clarification of MiFID II requirements on recording telephone conversations during COVID-19
ESMA clarifies that investment firms must adopt alternative arrangements, such as recordable electronic communications, when standard recording processes cannot be implemented due to exceptional circumstances like remote work. If voice recording remains impracticable, firms are expected to mitigate risks by taking written minutes or notes of conversations, provided clients are informed beforehand and enhanced monitoring is applied. These measures must remain temporary, with firms required to restore full compliance with existing recording requirements as soon as possible.
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