Compliance devices lack verification

The SPOT 2025 audit by the AMF reveals that while companies know how to record calls, they often fail to verify that the recording actually works. This highlights a critical gap in how compliance is managed in financial services.

Decline of voice orders raises risks

The use of the telephone for order execution is declining, with only 19% of asset management companies surveyed by the AMF still using voice orders in summer 2025. However, the regulatory risks associated with this channel remain significant and may even be harder to manage as it becomes less central.

Compliance shifts from equipment to oversight

Traditionally, compliance was viewed as ensuring the right equipment and procedures were in place. However, the SPOT audit shows that the real challenge now is knowing whether the system is actually capturing what it should. This requires ongoing oversight, not just initial setup.

Technology alone is not enough

Even with the right tools in place, companies may fail to ensure they are used properly. The AMF found examples of lines being recorded late, calls not being captured, and employees manually interrupting recordings. This shows that the issue is not just about technology, but about monitoring its use.

Smartphones highlight oversight gaps

In five companies reviewed, mobile communications were recorded using an app connected to the company's system. However, none checked whether employees used the app instead of their phone’s native function or other channels. Some employees even used alternative methods for communication.

Modern telephony demands continuous monitoring

With the rise of smartphones, remote work, and various communication tools, compliance must be more than just a one-time setup. It must be observable, allowing companies to detect when recordings are missing or when devices change. This requires a shift in how compliance is managed.

Verification of recordings is crucial

The SPOT campaign found that some companies could not provide requested recordings of voice orders. In one case, orders were placed using an unrecorded phone, and the files had to be retrieved from the broker. This shows that a recording system is only useful if it can be relied upon when needed.

Retention policies need verification

While some companies follow retention rules, the AMF emphasizes that these are only effective if the company can confirm they are applied. Files must be present during the required period, deleted at the end, and accessible when needed. This requires active oversight, not just policy.

Internal controls often miss issues

Despite having formalized controls, some companies failed to detect issues like recording failures or the use of unrecorded phones. This shows that the real danger is not a system failing, but a failure going unnoticed. Supervision must be an integral part of compliance.

Compliance must be treated as critical infrastructure

The AMF concludes that telephone compliance should be managed like a critical infrastructure. It requires regular checks, alerts, and testing to ensure it functions as intended. Without active supervision, even the best recording systems may not provide the evidence needed when it matters most.