FCA Review on Off-Channel Communications: Key Findings

On 7 August 2025 the Financial Conduct Authority (FCA) published the findings of its multi-firm review into off-channel communications. These are business-related discussions that take place outside approved monitored systems. The review highlights ongoing risks and control weaknesses across wholesale banking and other FCA-regulated firms.

The FCA confirms that while all sampled firms have made notable improvements over the past two years, breaches of internal policies remain frequent. 41% of incidents involved staff at director level or above. Although these breaches were not automatically violations of SYSC 10A rules their persistence shows a need for stronger behavioural controls as well as better detection systems.

Best practices observed include:

• Updated policies covering modern communication tools including wearables such as smartwatches.

• Streamlined processes for staff to self-report off-channel messages.

• Restricted use of personal contact details in business directories and out-of-office replies.

• Centralised reporting lines and targeted training for high-risk staff functions.

Third-party vendor solutions presented further challenges such as; service outages, data lapses and reconciliation issues. These have become common issues.

The FCA continues to urge firms to assess whether leadership sets a strong enough compliance tone, employees understand their surveillance obligations, monitoring reflects business models and management information (MI) leads to corrective action.

Why This Matters for Your Firm
Many firms are now seeking independent audit support or remediation oversight to strengthen frameworks, verify surveillance completeness, enhance training and ensure robust third-party vendor controls. Objectivus is well placed to assist. Please contact us to discuss how we can support your compliance roadmap.

Please reach out to info@objectivus.com if you have any questions or require further clarity on any of the points raised.