Resulting from the in 2014 introduced Markets in Financial Instruments Directive (MiFID II, article 16) and the Markets in Financial Instruments Regulation (MiFIR), there are more extensive requirements for recordkeeping. By January 3rd 2018, banks and investment companies should be in a position to archive, supervise and disclose all their electronic communications, including voice, from any device, personal or business. This means that within the organizations a reliable and safe system should be implemented which not only ensures the recording and archiving of data but also provides the ability to quickly provide any information when needed.


Summarized, the MIFID II requirements are as follows:


  • A bank or investment firm shall arrange for records to be kept of all services, activities and transactions undertaken, which shall be sufficient to enable the competent authority to fulfil its supervisory tasks.
  • Records shall include the recording of telephone conversations or electronic communications relating to, at least, transactions concluded when dealing on own account and the provision of client order services that relate to the reception, transmission and execution of client orders.
  • Such telephone conversations and electronic communications shall also include those that are intended to result in transactions, even if those conversations or communications do not result in the conclusion of such transactions or in the provision of client order services
  • For those purposes, an investment firm shall take all reasonable steps to record relevant telephone conversations and electronic communications, made with, sent from or received by equipment provided by the investment firm to an employee or contractor or the use of which by an employee or contractor has been accepted or permitted by the investment firm.

CyberTwice provides a cloud-based (mobile) call recording and archiving solution which helps, financial institutions as well as government and large organizations to archive all call data. The system consists of the eRecorder HD, which is installed by the (mobile) network provider in its core network, and an MMA media archiving solution which is installed within the organization itself. The systems provide a highly secure recording, archiving and indexing of all (mobile) call data. By implementing such a system, the MiFID II requirements can be met in the most effective, affordable, secure and scalable way.