The New Off-Channel: Written by AI, Owned by You

Off-channel once meant WhatsApp or Signal. Now it’s Copilot, ChatGPT, and every other AI assistant quietly drafting emails, memos, and client updates inside your firm.

When a banker types a prompt like “Summarize this client call” or “Write a response to the investor,” that interaction is a communication.

Under FINRA 2210 and 3110, if it relates to business, it must be captured, retained, and supervised.

“For those of you that are in the regulatory frameworks, you understand the custodian and the need to preserve the custodian’s data. What if I was to tell you that custodian is no longer an employee? It’s Copilot.”
— Irfan Shuttari, GITEX 2025

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AI may write the email. But you still own the words—and the risk.

Your Data’s Going In — and Coming Back Out

Each prompt sent to an AI model carries client data, product details, even draft disclosures. Each output coming back shapes a decision, a message, or an external statement.

That two-way flow means AI is no longer just a productivity tool; it’s a communications channel. And like every other channel before it—email, chat, voice—it’s now squarely in the regulator’s sights.

The question isn’t if AI communications will be reviewed. It’s when, and whether you’ll have the records to defend them.

“The challenge then for compliance becomes—how are we capturing that data?” — Irfan Shuttari, GITEX 2025

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The Four Pillars: Where Governance Must Catch Up

1. Speed — Faster Than Any Channel Before
   Generative AI reached 39 % workforce adoption in under three years—faster than PCs or the Internet. Your employees are already using it. Your supervision program probably isn’t.
2. Scale — Already in Your Comms Stack
   Over 60 % of large enterprises use AI to write or summarize content—from analyst notes to client letters. If AI helped shape a communication, it falls under existing rules.
3. Usage — The Hidden Volume
   A typical enterprise now processes about 50 million tokens of AI content each month—roughly 600 books or 25,000 emails a day. That’s invisible traffic moving through your systems with no retention policy.
4. Gap — Governance Hasn’t Caught Up
   Fewer than 1 in 5 organizations have an AI governance board. Regulators aren’t waiting for the other four out of five to catch up. Neither should you.

You Don’t Need a New Program. You Need Control.

The answer isn’t a parallel compliance stack. It’s extending what you already have:

• Capture and index prompts + outputs alongside email and chat.
• Tag them with model, user, and context metadata.
• Apply your existing lexicons and supervision workflows.
• Keep audit trails for traceability and explainability.

Compliance has never just been about storing content. It’s about understanding how that content was created and by whom.

“Here’s the gap—the big bad wolf at many organizations is that AI governance board. They’re asking: How are you going to use this technology? How is it going to be secured? What frameworks do you already have in place?”
— Irfan Shuttari, GITEX 2025

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How Arctera Insight Closes the Gap

Arctera Insight extends enterprise compliance to AI communications by capturing and governing the machine conversation the same way you manage the human one:

• Secure API integrations for Copilot and OpenAI.
• Archiving of prompts, responses, and model metadata.
• Automated supervision and alerting under existing policies.
• Unified review across email, chat, voice, and AI.

So when regulators ask for “all communications related to X,” you can produce not only the email but the AI-draft that shaped it.

The Takeaway

AI is already in your communications. Your employees are using it, your regulators are learning about it, and your governance board is asking questions about it.

The firms that treat AI interactions as governed communications will stay ahead of the enforcement curve. The rest will be defending decisions they can’t reproduce.

Governance isn’t about slowing innovation—it’s how organizations scale it responsibly. When AI becomes part of communication, it must also become part of compliance.

Download "Building Trust in AI Communications" and see how regulated enterprises are turning governance frameworks into everyday assurance—capturing, supervising, and archiving AI-assisted communications with confidence.