Emojis in Business are the New Face of Compliance Risk

Ten years ago, Oxford University Press awarded the 2015 Word of the Year title to “😂”. In the intervening decade, emojis have continued to embed themselves in written language: they’re now used by 92% of internet users worldwide. They've spilled over from informal texts to work-related communications, accelerated by a rise in business instant-messaging platforms like Slack, Microsoft Teams, and WhatsApp Business.

While these pictograms have undoubtedly eased international communication, they also present a series of technological and social challenges, particularly when used in more strictly regulated industries like finance.

After the cryptocurrency giant FTX spectacularly collapsed in 2022, details soon emerged on the regulatory mismanagement that permeated the organization. One attention-grabbing example was the common practice of approving transactions and employee expenses via emoji reactions on Slack. At the time, this revelation caused an understandable stir, typifying FTX’s passive approach to compliance and record-keeping.

A few years later, the role of emojis in business communications has evolved. They are now a standard feature of corporate communication apps, welcomed by some for their ability to straddle borders and language barriers, and rued by others for their ambiguity, informality, and potential for misinterpretation. For financial institutions that face stringent communications regulations, emojis present a unique challenge. Organizations must find a way to balance ease of communication and employee preferences with accurate recording and clear correspondence. One thing is certain: emoji usage in the workplace is rising.

With the emoji-native Gen Z and Alpha demographic making up a growing sector of the workforce, is it time to rethink the role of the emojis in compliance solutions for banks?

Emojis in business communication

Work-based messaging platforms like Slack and Microsoft Teams have responded to the growing demand with extensive emoji, GIF, and sticker options for users to choose from. Meta's WhatsApp Business service now has over 200 million regular users, further normalizing emojis and ideograms in a work context.

A vital aspect of diligent compliance is the ability to record every possible channel used for business communication, both desktop and mobile. Emoji capture has become a standard expectation for corporate compliance and a requirement from most regulatory bodies.

1GLOBAL compliance products like Message+ directly address this need by unifying WhatsApp and SMS messages in the Microsoft Teams app, allowing employees to manage all business communications through a single hub. This unique multi-channel recording solution provides employees with the flexibility and efficiency needed to manage business conversations across multiple platforms, while ensuring rigorous recording and compliance in line with industry regulations. It also helps to support secure bring-your-own-device (BYOD) policies, enabling team members to use their preferred personal devices for work communications while maintaining responsible record-keeping.

What is Unicode?

Unicode is a set of standards for digitally rendering written characters in multiple languages and writing systems worldwide. Items written in Unicode will be seen as the corresponding letter, character, pictogram, or emoji by the end-user. “U+1F60A” for example, renders as 😊. Unicode is an essential element to compliant recording and recordkeeping, as it depicts the exact characters written in any communication, even if the emoji or pictogram fails to render.

High-level mobile recording services like 1GLOBAL Compliance capture both the pictographic emoji as well as the underlying Unicode text to minimize any ambiguity or rendering issues when capturing emojis in business communications. Even with these measures in place, however, pictograms still present a host of issues for compliance teams, regulators, and employees.

Emoji compliance challenges

1. Varying interpretations

The differing cultural contexts of different emojis leave them far more open to interpretation than words. This ambiguity can be a nightmare for corporate compliance departments. Some are widely-understood stand-ins for NSFW or politicized terms, which present a host of ethics and behaviour issues quite outside of compliance. Others, like the nail-painting emoji, have taken on a particular meaning that words can't truly capture ( let alone with the compact efficiency of 💅). And while most emojis break down language barriers, many have particular social and regional interpretations that can hinder cross-cultural communication.

2. OS and app differences

This potential for ambiguity is complicated by the fact that different operating systems and apps render Unicode differently, resulting in slight variations in emoji appearance. This platform-based variance can have far-reaching consequences: in 2020, the actor Jameela Jamil used an iPhone to retweet an image of shoppers facing empty shelves during the height of the COVID-19 lockdowns. On an Apple device, this rendered as a sympathetic response. For other Twitter users, however, it appeared to be an amused face, forcing Jamil to publicly apologize and delete the tweet.

Even for corporate clients and financial institutions with their own device fleets, the wide range of business messaging platforms and apps means there's always a risk of variance in emoji appearance, and possibly interpreted meaning, between the sender and receiver.

For financial institutions, this raises serious compliance challenges. Emojis may create uncertainties and gray areas in messages that words would not. A text-only capture system may not accurately capture emojis, potentially missing critical information.

Today, most organizations prefer a network-based recording solution like that offered by 1GLOBAL. This offers 360° recording of all device communication channels and, unlike app-based recording systems, can be quickly and flexibly rolled out to devices with different operating systems and manufacturers. It also records the Unicode text for all characters, providing a definitive record of the intended appearance of every message.

3. Regulatory gaps and expectations

Emoji capture is a standard feature of compliance recording software, and an essential requirement for any contemporary financial institution. Industry regulators must deliver a clear stance on their usage, capture, and interpretations. Companies themselves must ensure their capture and recording solutions are capable of handling Unicode, and that their teams receive ongoing training on appropriate usage, intent, and cultural contexts of new emojis. Industry-wide enhanced monitoring needs are essential to ensure ongoing responsible communication and compliance in the financial sector.

The accepted use of emojis in business communications is indicative of the gradual convergence of business and personal messaging norms. As instant messaging services like WhatsApp and Slack continue to gain a foothold in the corporate sector, they shape the ways that we communicate.

While this progression can make workplace communication faster and more convenient, it’s increasingly exposing legacy compliance systems. Disentangling the multiple messaging platforms used by modern businesses is futile. A holistic recording approach is a requirement for any contemporary financial institution.

Progressive compliance solutions

Regardless of these challenges, the reality is that emojis have become an inextricable element of personal and work-related language. An Atlassian survey found that 88% of Gen Z respondents found emojis useful in work messages. Further non-verbal formats like GIFs and stickers present similar challenges and opportunities for financial institutions. Regulatory bodies, mobile OS developers, and employees recognize this. In 2025, financial institutions must have a compliance strategy that does too. Solutions for ensuring reliable and responsible emoji usage and recording rely on several factors:

1. Training and sensitivity

• Providing ongoing training for employees on cultural awareness, context sensitivity, and emoji usage in professional communications. 

2. Comprehensive compliance and recording solutions

• Tools for capturing emojis in messaging platforms, taking into account the wider context, cultural factors, and true intent.

• High-level compliance tools like 1GLOBAL that can accurately capture and record emoji communications and produce these records when required.

• Constantly evolving work messaging norms and the regulations that police them require a flexible, scalable compliance service that can adapt to new guidelines and behaviours. Companies must be proactive with their compliance services, adopting a solution that allows them to stay ahead of the regulatory curve.

3. Regulatory guidelines

• Establishing and maintaining regulatory frameworks that address the realities of contemporary digital communication. Both the UK’s FCA and the USA’s SEC regulatory bodies recently altered their criteria to allow for greater flexibility and pragmatism in business communication.

1GLOBAL Compliance

1GLOBAL Compliance offers a truly international solution for mobile recording for banks that ensure adherence to the latest compliance standards and accurately capture calls, messages, and digital symbols like emojis. Through a single provider, businesses can securely manage all connectivity users, administrators, phone numbers, alerts, and more via a single centralized platform. A geo-redundant network and suite of innovative compliance tools like Message+ have made us the preferred compliance partner for the world's largest investment banks.

Find out how 1GLOBAL can help you easily and comprehensively meet your compliance obligations by speaking to our team today.