Does Compiled replace our existing supervision workflow?

No. Compiled surfaces findings into your existing SIEM, SOAR, and case-management tools. Your reviewers work in the systems they already use. Compiled adds behavioral coverage and a real-time decision layer that your existing tools do not provide.

How does Compiled handle off-channel communications on personal devices?

Compiled connects to the communication channels and collaboration platforms your firm has authorized for business use. For off-channel channels that cannot be monitored by policy, Compiled can be configured to flag any attempt to direct conversation to an unmonitored channel — surfacing the evasion attempt itself as a finding.

Can we encode our own written supervisory procedures?

Yes. Enterprise subscribers compile their firm-specific supervisory procedures into antibodies. A policy stated in plain language becomes an encoded, enforced recognizer operating inside your environment. Findings carry the name of the specific procedure they matched.

How does the self-reporting cooperation credit angle work in practice?

Regulators have made clear that cooperation credit requires proactive disclosure of violations discovered through a firm's own supervisory program. Compiled gives you a real-time detection capability. When a potential violation surfaces, it is time-stamped, scored, and attributed to a specific policy — the kind of documented discovery that supports a credible self-report and cooperation narrative.

SEC and FINRA Compliance

Regulatory landscape

The rules and what they require

Three overlapping frameworks govern broker-dealer and registered investment adviser communications. Each carries independent examination exposure, and together they define the minimum surveillance program a CCO must be able to evidence.

FINRA Rule 3110

Supervision of electronic communications

Rule 3110 requires member firms to establish written supervisory procedures and review electronic communications for violations of applicable rules. The obligation is technology-neutral: it applies to any channel employees use for business communications — including personal devices and third-party messaging platforms. Firms must be able to demonstrate that a reasonable supervisory system was in place and operating.

Written supervisory procedures covering all electronic communication channels
Review of a reasonable sample of outgoing communications
Escalation and documentation of identified violations
Annual certification by a principal of the adequacy of the supervisory system

SEC Rules 17a-3 and 17a-4

Recordkeeping and electronic storage requirements

Broker-dealers must preserve all business-related electronic communications for a minimum of three years (first two in an accessible place), in a format that is non-rewritable and non-erasable (WORM). The SEC has consistently treated failures to capture off-channel communications as recordkeeping violations, not merely supervisory ones — which is why the penalty figures are as large as they are.

All business-related communications captured and preserved, regardless of channel
WORM-compliant storage for the required retention period
Audit trail demonstrating when records were created and accessed
Ability to promptly produce records in response to an examination request

Trade surveillance

Detecting insider trading, market manipulation, and front-running

FINRA Rule 3110 and the SEC's anti-manipulation provisions (Section 9 and 10(b) of the Exchange Act; Rule 10b-5) require firms to surveil for conduct that could constitute market abuse. The obligation is behavioral: keyword matching is not sufficient to satisfy an examiner who asks whether the firm would have detected a specific pattern of misconduct.

Cross-channel correlation of communications and trading activity
Detection of coordinated trading patterns and information leakage
Surveillance for front-running and pre-announcement trading
Documented escalation process for flagged activity

Enforcement reality

The floor did not move. The enforcer did.

SEC Chair Atkins characterized the off-channel sweep at the FINRA Annual Conference in May 2026 as a model of how regulators should not act and signaled that regulation-by-enforcement is over at the SEC. FY2025 saw roughly 456 actions — a 20-year low. But in February 2026, the off-channel charge in SEC v. Arete Wealth survived a motion to dismiss. The court was direct: "the rules say what they say."

The practical implication is a shift in leverage, not a reduction in obligation. The dominant lever is now self-reporting and demonstrated cooperation. PJT Partners received a $600,000 penalty against a peer average of $8.5 million — a difference attributable to cooperation credit. Firms cannot self-report what they cannot detect. Detection tooling is no longer a cost center; it is the instrument of the cooperation credit program.

An interagency AI/MRM request for information is announced, and 2026 examination priorities verify AI-related claims in virtually all examinations. The same supervisory infrastructure must now also be able to speak to how AI agents operating in the firm are controlled.

Risk scenarios

Where exposures arise in practice

Off-channel coordinationBlock

A portfolio manager and an analyst discuss a pending acquisition on a personal messaging app before the announcement. The firm's keyword filter sees nothing because no prohibited terms appear. Compiled recognizes the behavioral pattern — coordinated information handling ahead of a material event — and flags it in real time.

Implicit trading recommendationFlag

A registered representative sends a client a message that does not explicitly recommend a security but structures information in a way that functions as one. FINRA Rule 2210 requires such communications to be fair and balanced. Compiled identifies the implied recommendation and flags it for principal review before the communication is sent.

Front-running signalFlag

A trader's communications show a pattern of discussing a client order's direction with a counterpart shortly before executing a proprietary position in the same instrument. No single message contains a keyword. The behavioral sequence across messages, correlated with trade timing, surfaces the pattern.

AI agent making investment-adjacent statementsBlock

An AI agent deployed for client service begins providing responses that imply portfolio direction in response to questions about performance. The firm has no real-time control plane on the agent. Compiled sits inline, flags the response before it is delivered, and routes the finding to the compliance queue with full policy attribution.

How Compiled works

Behavioral detection, in-tenant, explainable

Compiled deploys inside your Azure tenant. Every communication and every AI-agent action is inspected inline, before it completes. Nothing leaves your environment.

Behavioral, not keyword

Antibodies recognize the conduct pattern — coordination, information asymmetry, implicit recommendation — regardless of the vocabulary used. Evasion by word choice does not work.

Inline verdicts

Allow, flag, or block decisions are rendered in real time. A flagged communication is held for principal review; a blocked one does not proceed. No action is first-seen in a next-day report.

Policy-linked findings

Every finding carries the specific policy or rule it matched — FINRA 3110, 10b-5, your own firm policy — so the examiner's question "what rule does this relate to?" has an immediate, documented answer.

Zero data egress

Communications are inspected inside your tenant. The surveillance tool your data-residency and privacy teams will actually approve — and no data-handling disclosures to regulators about vendor cloud access.

Routes to your SIEM

Findings surface in the SIEM, SOAR, and case-management tools your team already uses. No new data home; no separate evidence repository to manage at exam time.

Your own policies

Enterprise subscribers compile their own written supervisory procedures into antibodies. The firm's specific restrictions become encoded, enforced recognizers — not a checklist that depends on reviewer judgment.

Examination readiness

What you produce for an exam

When FINRA or an SEC examination staff requests evidence of your supervisory system, Compiled produces a structured, exportable record from inside your own environment. No data needs to be assembled from multiple systems or reformatted for production.

TimestampUTC timestamp of the communication or agent action, to the millisecond

ChannelEmail, Teams, Slack, or the specific agent framework — preserved in the finding

VerdictAllow, flag, or block — with the decision rendered before the action completed

ScoreBehavioral risk score against the matched policy, calibrated to your environment

Policy attributionThe specific rule or firm policy matched — FINRA 3110, Rule 10b-5, or your written supervisory procedure

Reviewer actionPrincipal review outcome and escalation log, if the finding was flagged

Storage locationFindings remain in your environment, exportable to your SIEM or case-management system

Real-time, explainable supervision of electronic communications.