Compliance fundamentals: Building a resilient and intelligent recordkeeping system

KEY TAKEAWAYS

What does a resilient recordkeeping system look like and what are the key components? This article looks at what a compliant capture and archival solution looks like and how digital communications and heightened enforcement have impacted recordkeeping compliance.

The landscape of compliance recordkeeping is undergoing rapid transformation as communication technologies evolve. Digital collaboration platforms, mobile messaging, and remote work have expanded the number of channels where regulated business occurs, introducing new risks and expectations.

This article, second of our two-part series on financial services recordkeeping, focuses on how enforcement trends are reshaping the compliance landscape and tips on what to include in a modern, effective capture and archiving solution.  

To read part one of this series, covering the foundational concepts of compliance capture and archival, click here. 

How digital communications are affecting recordkeeping complexity 

Digital collaboration tools, mobile messaging, voice and video conferencing, and in-app chats have multiplied the places where regulated business occurs. Remote and hybrid work have expanded channel variety, and with it, the risk of off-channel communications that are not captured. 

Regulators have responded with sustained enforcement actions focused on recordkeeping requirements. Recent examples include: 

• Aug 8, 2023: the SEC charged 11 firms and announced $289 million in penalties “for employees using unofficial communications like WhatsApp, personal texts or email to conduct business”.  

• Aug 14, 2024: the SEC announced actions against 26 firms with combined civil penalties of $392.75 million after they “failed to keep their employees’ electronic communications”. 

• Jan 13, 2025: Robinhood agreed to pay $45 million to settle SEC charges that included “not preserving electronic communications records, among other securities law violations.”.  

Although the pace and size of headline-grabbing enforcement fines appear to have cooled as of the time of this writing (Q1 2026), regulators maintain a keen eye on books and record retention and continue to audit violations as part of their regular and routine inspections.  

From enforcement to action: What a compliant capture and archival solution looks like  

Each enforcement tells the same story, that incomplete or inconsistent data capture can undermine a firm’s ability to show compliance. The question becomes: what should a compliant capture and archival solution look like? 

Data capture  

A robust data capture solution is the foundation of effective recordkeeping and regulatory compliance. Its purpose is to collect, normalize, and preserve business communications and transactional data from every relevant source, ensuring that no regulated activity escapes the firm’s official record. 

Scalability and resilience 

Capture systems need the capacity to handle large and fluctuating data volumes, all while maintaining high availability and fault tolerance. 

A resilient capture framework typically includes: 

• Load-balanced ingestion pipelines to handle burst traffic (e.g., during market events). 

• Automated retries and failover mechanisms to prevent data loss. 

• Integrity validation checks (hashing or checksums) to confirm that captured data matches the original communication. 

• Encrypted transfer and storage to ensure confidentiality during capture and transit. 

Compliance and evidence of completeness 

Regulators often require firms to demonstrate not only that data is captured, but that capture processes are complete, reliable, and auditable. Effective capture systems therefore generate: 

• Capture logs documenting every message successfully ingested or failed. 

• Channel coverage reports for audit review or regulatory exams. 

• Exception alerts when expected data streams stop or degrade, enabling prompt remediation. 

This evidentiary layer is crucial for compliance testing, internal audits, and demonstrating that the firm’s “books and records” reflect all relevant business activity, not just a subset of channels. 

Archival and search capabilities 

Archival systems hold highly sensitive and regulated data, so security is mission critical. Core controls include strong encryption, granular access management, segregation of duties, comprehensive audit logs, and chain-of-custody reporting. Certifications such as SOC 2 Type II and ISO 27001 support vendor due diligence. 

For regulated firms, electronic record-keeping systems must comply with strict standards to ensure the integrity and accessibility of stored information. Some regulations require non-rewriteable, non-erasable storage on write-once, read many (WORM) drives to prevent alteration or deletion. Other regulations permit a compliant audit-trail alternative that maintains a complete, time-stamped history of changes and preserves the authenticity, accuracy, and availability of the original records. 

Archived data must also be quickly and accurately searchable as firms are required to respond “promptly” or “without delay” to regulator requests. Many firms adopt internal service levels of a few hours to several days for delivering trade reconstructions and record sets, even where no explicit time limit is stated. 

Intelligent search and investigation tools 

Some capture and archiving solutions also include embedded surveillance capabilities, relevant since surveillance obligations are closely linked to recordkeeping requirements. These tools store data securely and enable proactive monitoring by alerting compliance teams to potential risks, misconduct, or policy breaches based on captured data. 

The ability to search, flag, and investigate suspicious activity directly within archived data is important to help strengthen compliance and risk management programs. 

Modern systems increasingly use AI, specifically large language models, to expand queries, interpret misspellings and code words, and surface related content while preserving exact originals. This is important because in some cases, users who intend to evade detection often misspell words or use euphemisms.  

Changing compliance archives and migration approaches 

Firms periodically need to reassess their archival platforms. This may be driven by several factors: 

• Long-term value: total cost of ownership has increased, or newer solutions offer lower cost and risk. 

• Outdated technology: limited channel coverage, weak search, or slow exports. 

• Control failures: gaps in capture, failed restorations, inadequate audit logs, or inability to meet basic requirements. 

• Consolidation: the desire to unify multiple archives or legacy systems into a single, more manageable platform. 

Once a firm determines that a migration is necessary, the next step is to plan how to transition records without compromising compliance, data integrity, or operational continuity. Successful migrations require careful sequencing, validation, and governance to ensure that historical data remains complete and accessible, and that new capture pipelines meet regulatory standards from day one. The right approach depends on factors such as data volume, system compatibility, retention periods, and the firm’s overall risk appetite. 

Migration approaches 

• Dualrun: for a defined period while validating capture completeness and exports from both systems. 

• Split archive: keep historical data on the legacy platform until retention lapses while sending new data to the new platform. 

• Full migration: move historical and new data to a single platform; reconcile carefully. 

• Hybrid: migrate high value or high-risk datasets first, then backfill the rest. 

In all cases, it is critical that firms define criteria for completeness, integrity checks, legal holds, and retention timers.  

Conclusion 

A strong compliance archival framework does more than just store data, it protects the integrity of operations and demonstrates accountability to clients, counterparties, and regulators alike. 

As communication channels proliferate and regulatory scrutiny deepens, compliance teams must think strategically about how data is captured, stored, and surfaced. The goal is not only to satisfy the letter of recordkeeping rules but to build systems that allow firms to reconstruct events, identify risks early, and respond confidently when questioned. The best systems combine comprehensive coverage, immutability, intelligent search, and robust governance. 

How Bloomberg Vault supports compliant data capture and archiving across jurisdictions 

Bloomberg Vault provides a suite of tools designed to help financial institutions meet their capture and archival requirements with confidence. Vault is built to support compliance across multiple jurisdictions while offering the flexibility and scalability needed to manage evolving communication channels and regulatory expectations. 

• Multi-channel capture: unified ingestion of email, chat, voice, mobile messaging, and collaboration data from a broad range of platforms. 

• Regulatory recordkeeping: immutable storage solutions that clients can configure to meet or exceed their global regulatory standards for records retention 

• Trade reconstruction and search: advanced tools for rapid retrieval and contextual reconstruction of communications and transactions to respond to regulatory inquiries. 

• Data residency and sovereignty controls: configurable storage locations and controls to support compliance with regional data-handling requirements. 

• eDiscovery exports: secure, defensible export capabilities to streamline investigations and legal or regulatory responses. 

Vault integrates capture, archival, and supervision into a single platform that helps firms protect their data, demonstrate compliance, and reduce operational complexity. 

To learn more about Bloomberg Vault click here.