See feature article below: The Goldman Sachs Group, Inc. (NYSE: GS)
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Report For: The Goldman Sachs Group, Inc. (NYSE: GS)
This article details the email monitoring process at Goldman Sachs. It also carries the unspoken implication that other employers could be involved in a similar compliance program. It’s a long article because it includes the 180 separate words / phrases that get flagged at Goldman.
Bankers at Goldman Sachs might want to think twice before sending an email calling any trade “a sure bet.” They may want to pause before they send a note saying someone “embezzled the account.”
And they probably don’t want to send an email using any one of 13 separate phrases that include the F-word.
That’s because Goldman Sachs’ compliance department conducts surveillance of employees’ email. It’s an automated process: Software monitors the emails for certain phrases that are flagged for specific scrutiny. Human employees at Goldman then review the flagged emails and decide whether they represent a problem.
CNBC has obtained a document detailing more than 180 phrases flagged for scrutiny by the monitoring system. The document was produced in 2008, and the firm has updated its search terminology since then. But the list gives a rare peek inside a large bank’s real-time compliance surveillance operation, and reveals details of how that process works that even veteran Wall Street executives may not know.
Attorneys for Goldman described the confidential document as “a lexicon of terms and phrases used by the Firm’s Compliance department for surveillance of the electronic mail of certain employees.” The source who provided the document asked not to be named.
Monitoring employee email is not necessarily nefarious. Banks typically do it to detect any early indicators of fraud. In fact, the Securities and Exchange Commission expects that banks’ policies and procedures will include monitoring emails. But the SEC has no specific rules or requirements as to the search terms banks use to do that.
A banking industry expert said technological monitoring of employees is increasingly common in the financial industry. “It’s not just email, it’s about using key words to monitor social media as well,” the expert said. “What the institution is trying to do is to flag activities that may be illegal or may represent insider trading.”
Examining the list, it seems clear that Goldman was looking for specific areas of concern: tense exchanges between bankers and their customers, disputes over commissions and money, or certain phrases involving obscenities.
Today, Goldman’s communications monitoring is more extensive than it was in 2008 and encompasses communications technologies beyond email. And rules about profanity in email have tightened. Goldman employees say the email system automatically pops up a window if a user attempts to send an email containing a bad word. The sender must click a box to demonstrate that he or she is aware of the expletive and approves sending it before the offending email will go through. Goldman’s employees are told their electronic communications will be watched.
“We deploy cutting-edge technology and exercise the utmost care to protect confidential information, secure data and provide high-end client service,” said a spokeswoman for Goldman Sachs. “The firm’s monitoring efforts reflect our commitment to upholding the highest standards of professionalism and integrity.”
The Goldman Sachs list was formatted in such a way as to capture phrases with different configurations that produce the same meaning, with word options for each phrase separated by brackets or lines. For example, one search term is: “I didn’t {authorize}|{agree}.” Presumably, that search term would capture anyone writing the phrase “I didn’t authorize,” or “I didn’t agree,” both of which might indicate some sort of dispute.
Goldman Sachs also monitored for email about calling financial regulators or organizations, including the SEC, NASD and New York Stock Exchange. One phrase that would be flagged: “Call the SEC.” And the system watched for “20549,” which is the ZIP code for SEC headquarters.
In places, the list reads like a thesaurus for synonyms for the entire range of emotions a banker or client could experience in the workplace. The longest search phrase on the list is this:
“I {was|am} extremely[?]{pissed|angry|concerned|upset|agitated|bothered|distressed|
perturbed|worried|vexed|confused|flustered|discouraged|
rattled|daunted|demoralized|disheartened|
dismayed|distraught|unnerved}}.”
Among the phrases flagged are seemingly innocuous phrases of daily office life: “answer your phone,” “don’t worry I’ll take care of it” and “I don’t understand.” Also to be scrutinized were “I’ve been trying to reach you,” and even “still have not received.”
There are a number of phrases linked to stock trading on the list: “Time to dump,” “break the trade” and “stock will fly/soar/dive/tank.”
And there are several phrases that might indicate a dispute with a customer, including “not made aware,” “I trusted you” and “I told you days/weeks/months ago.” And particularly, “paying fees through/thru the nose/a–/butt.
Some of the phrases could be indicators of possible fraud, including “adjust your account,” or “clowns managing/running the fund/show/portfolio/account/my money.”
And no list like this would be complete without the myriad inventive ways bankers find to use of the F-word, including: “don’t you f—ing understand,” “mad/angry/frustrated as hell/f—,” “Screw/f— it up,” “way to f—ing much,” “what I f—ing said,” “where the f—/hell are you,” “who the heck/f—/hell do you think you are,” and “don’t you f—ing understand.”
That obscenity list, the banking industry expert said, could flag a large number of emails. “You’re probably going to get a variety of false F-bomb positives that you don’t want to explore any further,” the expert said.
Does all this electronic monitoring actually work? It’s hard to say. Despite the electronic snooping, it seems that some problems manage to crop up time after time.
One phrase the Goldman software searched for: “How could this happen again?”
Read Goldman’s list:
a sure {bet}|{thing}
adjust your account|losses|profits
against my expressed[?] wishes
answer {your}|{the} %ANY%[0\,3] phone
are {not responsive}|unresponsive
bad to worse
charge in excessive amount
charged {too much}|{excessively}
close|end|terminate my %ANY% [1\,5] relationship with GS|Goldman|{this firm}
Clowns {managing|running} the fund|show|portfolio|account|{my money}
concern* %ANY% [1\,5] safety of my money|fund|account
cover {your}|{our} losses
didn’t authorize the sale
didn’t|didnt|{did not} explain to me|us
disturbs|troubles me|us
don’t worry i’ll take care of it
don’t you f*cking understand
done|{did this} without %ANY% [1\,5] calling|emailing|contacting me|us|anyone
embezzled the account
extremely|really|quite|very unhappy|disappointed
failed to execute {our}|{my}instructions
fix the {trade}|{trades}|{commissions}
fix|adjust|change the trade*|commission*
formally|formal complain|complaint
found numerous|several errors|mistakes
give you a piece of {the}|{my} commission
how could this happen again[?]
How could you|GS|Goldman possibly[?] lose so|this|that much
I %ANY% [0\,4] {losing}|{lost} patience with {you}|{GS}|{Goldman}
I am not a happy camper
I didn’t {authorize}|{agree}
I expect {a|an|your}[?] {answer*|response} {today|now|asap}
I|we have lost|{run out of}|{ran out of} confidence|faith|trust|patience
I have raised %ANY% [1\,5] at least %ANY%[1\,3] times
I have raised %ANY% [1\,5] so many times
I lost {exorbitant|enormous amounts of}|{so|too much} money
I told you %ANY% {days|weeks|months} ago
I told you %ANY%[0\,1] {days|weeks|months} ago
i want the %ANY%[0\,2] trade reversed
I wanted out of %ANY%[3] {stock | {hedge fund} | fund | account | position}
I won’t|wont|{will not} pay for the|this trade
I {don’t}|{dont}|{do not} understand
I {trusted}|{believed in}|{had faith in} you
“I {was|am} extremely[?]{pissed|angry|concerned|upset|agitated|bothered|distressed|
perturbed|worried|vexed|confused|flustered|discouraged|
rattled|daunted|demoralized|disheartened|
dismayed|distraught|unnerved}}.”
I {would appreciate}|want {a|an} {call|email}
if this {doesn’t} | {does not} get resolved|fixed soon|immediately|{right now}
incompetent|inept fund|account management
increasingly|really getting[?] frustrated
it is your | goldmans | {goldman’s} job to make sure
I|we demand
I|we will not pay
lack of care|attention %ANY% [1\,5] my money|account*|fund*
let me remind you
losing confidence|faith|trust|patience
mad|angry|frustrated as hell|f*ck
make it up to you
my repeated {requests}|{request}
no longer be doing business
No one {called|emailed|contacted}
no one {{gave you}|{had} permission}|{said you could}
not %ANY%[0\,1] reasonable
not even one phone[?] {call} | {email} | {word} from {you | goldman}
not made aware
not {heard {back[?]} from you}|{what we agreed}
Paying fees {through|thru} the {nose|a–|butt}
phone {calls}|{call}e-mail{have}|{has} not been answered
piece of sh*t
pissed|pisses me off
poor|terrible|crappy {fund|account|portfolio}[?] results|performance
really %ANY%[0\,2] pissed|{PO’d}
rebate|refund my|your loss*
rebate|refund what I lost
register that|this as a complaint
remedy the situation
report the matter to the {sec}|{nasd}|{nyse}
reverse the commissions
reverse {this}|{the} %ANY%[0\,5] {trade}|{transaction}
screw*|f*ck* it up
so frustrat*
something {went}|{is really}|{will go} wrong
split the difference
statement complaint
still have not received
stock will {fly}|{soar}|{dive}|{tank}
supposed to be the top|best financial company
surprised|concerned|frustrated|angry that you didn’t|{did not} contact|call|email me
take care of any fees|commissions
taken advantage of {{the exemption in Financial Reporting Standard} | {the following exemptions on the first time adoption} | {any of the relaxed hedge accounting requirements} | {passport\\, this will still be subject to}úLSE%}[?]
That’s not what I {said}|{told you}
the {deal | account | fund | trade | trades} {was | were} not handled properly
there is a %ANY%[0\,3] problem
there is|are|{appears to be} a|several mistake*
there was an|a error|mistake
These managers give me a really[?] bad feeling
this is %ANY%[0\,5] totally[?] unacceptable|{not acceptable}
this is not fair
this won’t|{will not} happen again
this {is not}|isn’t|wasn’t|{was not} the %ANY% amount|{correct price}|price|stock|{correct stock}
This {part of the}[?] portfolio is[?] completely[?] sucks|stinks|f*cked up|{messed up}
time to dump
trades could|should be cancelled|reversed
transfer my {account}|{funds}immediately
troubles|disturbs|{disturbing to} me how long follow-up has taken
undo|break the trade
way too f*cking much
what happened to %ANY%[0\,5] money
What happened to my {money}|{account}|{trade}|{funds}?
what i f*cking said
what the hell|f*ck|heck {are|is} {you|GS|Goldman} doing with my|this|the {money|account|trade|funds|savings|portfolio}
what the {f*ck}|{hell}|{heck} {happened}|{is going on}|{is happening} with|to my|the|this {account|money|trade|fund*|savings|portfolio
Where did my {money}|{funds}|{account} go
where the {f*ck}|{hell} are you
who can I escalate the|this matter|issue|problem
who the {f*ck}|{hell}|{heck} said you could
who the {heck}|{f*ck}|{hell} do you think you are
who {supervises}|{manages} you
why should I|we pay
why {haven’t}|{didn’t} you {return}|{returned} my {call}|{calls}
won’t be doing business with you|GS|Goldman
worst investment
wrong amount|price|{number of shares}|stock
You didn’t follow my {instructions}|{wishes}|{plans}|{objectives}
You didn’t {tell me}|{say} that
You never {told me}|{said} that
you said you would {redeem|sell}
You stole from {me}|{my account}
you told me there {was no}|{wasnt any}|{wasn’t any} {downside risk}|{risk involved}
you were not up front
you werent|weren’t|{were not} authorized
you {didn’t}|{did not} | {didnt} {%ANY%[?] listen}|{supervise}
you {didn’t}|{did not}|{didn’t} {answer the question} | {reply}
you {f*cked}|{messed}|{screwed} up
you {have to}|{must} buy this stock
your|Goldman’s failure to comply|respond
you|GS|Goldman failed to comply|respond
{Call the SEC} {%precededby% {{Please. 20549}|{Please. D.C.}úLSE%}[?] } | {{{at 1-800-sec-0330} úlse%}[?]}
{contact}|{call the} {appropriate[*]} {authorities}|{regulators}|{nasd}|{nyse}|{sec}
{did not}|{didnt}|{didn’t} have permission to {buy}|{sell}|{trade}|{exchange}
{do not}|don’t have the confidence|faith|trust|patience to continue
{does not}|doesn’t|don’t respond|reply to my calls|emails
{don’t}|{dont}worry about the losses
{have|has} not received {the paperwork} | {any calls}
{I am}|I’m {%ANY%[0\,2]} {pissed off}|furious|irate|livid|incensed|upset|angry
{I am}|I’m|Im {not satisfied}|unsatisfied|dissatisfied
{i promise this time}|{this time i promise}
{i’ll}|{I will} fix {everything}|{it}
{i’ll}|{I will} work it out
{i’ve been trying}|{i’ve tried} to reach you
{i’ve}|{I have} been {unable}|{unsuccessful}trying to reach you
{i’ve}|{I have} contacted {my}|{an}|{your} attorney
{It’s|it is} %ANY%[0\,2] impossible to understand what|{what is} {{going on}|happened|occurred}
{I}|{Goldman Sachs}|{the firm}|{we} will make up the losses
{I}|{Goldman Sachs}|{the firm}|{we} {guarantee*}|{promis*}|{swear*} that[?] this won’t|{will not}|{will never} happen again
{I}|{we} will sue {you}|{your firm}|{Goldman}|{GS}
{I}|{we} will take you to court
{misrepresent}|{misrepresented}|{misrepresenting}|{misrepresents}
{regarding}|{concerning} your problem
{should have}|should’ve been bought|sold|done %ANY% [1\,5] ago
{transactions}|{transaction}|{trade} {was}|{were} never executed
{transfer|sale} still {hasn’t}|{has not} {happened|occurred}
{where have you been}|{where the {f*ck}|{hell}|{heck} have you been}
{who is}|{i want the name of} your {supervisor}|{manager}
{you’re}|{you are} a piece of sh*t
{your|these}{behavior|actions} are %ANY%[0\,1] {unacceptable|{not acceptable}}
{You}|{Goldman Sachs}|{the firm} were|was not authorized
{you}|{Goldman Sachs}|{your firm} personally guaranteed
{you}|{Goldman Sachs}|{your firm} will be hearing from my {attorney}|{lawyer}
{you}|{Goldman Sachs}|{your firm} {messed}|{screwed} up
{you}|{Goldman Sachs}|{your firm} {won’t}|{will not} get away with this
{mistake|error} on {your|GS|Goldman*} part
receiv* a|any|no response to my {email}|{call}|{inquir*}|{question*}|{complaint*}
{I}|{we} {did not}|{did’nt}|{didnt} receive|get a response
negatively affected by this|these %ANY%[0\,5] change*|error*|mistake*
{please let me}|{allow me to} address your {concerns}|{confusion}|{problem}
missing money|funds
{not happy}|unhappy|dissatisfied with the {way}|{manner} in which this is being handled|addressed|resolved
not happy|satisfied|content with the way GS|Goldman|you is|are handling|resolving|addressing this
GS|Goldman is really upsetting|frustrating me
{I don’t think this is}|{this is not}|{this isn’t} the type of customer service I deserve|expect*
avoid this kind|type of error|mistake|fumble|misstep|slipup|{foul up}|stumble
{please let me}|{allow me to} provide %ANY%[0\\,5] a|an reason|explanation
{I have}|{i’ve} been {unhappy}|{displeased}|{unsatisfied} with the {firm’s attitude}|{attitude of the firm}
I am {unhappy}|{displeased}|{unsatisfied} with the {firm’s attitude}|{attitude of the firm}
{I have}|{I’ve} found the {direction|attitude} of the firm {troubling|worrisome|disturbing|concerning|demoralizing|aggravating|perturbing|distressing|discomforting|disconcerting|demoralizing}
{I|we} find the {direction|attitude} of the firm {troubling|worrisome|disturbing|concerning|demoralizing|aggravating|perturbing|distressing|discomforting|disconcerting|demoralizing}
{my|our} {low|unsavory} view of {GS|goldman|{the firm}}
Not For[?] Communicat*|Distribut*|send*|delive* Outside %any%[\,2] Firm|GS|{goldman sachs}|goldman
for internal use in the offices of
internal only
internal u.s.e. only
{internal use only} { {%precededby% { {private|your | { for and confidential deemed is message this in } }úlse%}} | {{%any%[\\,2] {to be completed by} | {checking account number} }úlse%} | {%any%[0\\,5] SMARTPlus}úlse% }[?]
{social security}|{soc sec}|soc|ss{{no|number|#}[*]}%#\d\d\d\p\d\d\p\d\d\d\d%
{account|acct|acc|act}{{no|number|#}[?]}{%#\d\d\d\p%[?]}{%#\d\d\d\d\d%}{%#\p\d%[?]}
Source – CNBC / Eamon Javers
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