Off-channel communications: What they are, why they’re still a compliance risk, and how to manage them

Off-channel communications are business-related messages sent outside a firm’s approved, captured channels, e.g. a trade discussed over WhatsApp, a client instruction sent by personal text, or a deal term shared on Signal. Since regulators require firms to capture, retain, and supervise business communications, an off-channel message that is never recorded is a compliance failure.