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Messaging Compliance in a Shifting Regulatory Landscape: The Current and Shifting UK Regulatory Landscape

Are you ready to learn how to implement electronic communications capture and supervision in your firm for better compliance and prevention of regulatory violations? Is messaging compliance giving your compliance function headaches. Welcome to a special 5 part blog post series on messaging compliance in a shifting regulatory landscape, sponsored by Global Relay. For this Part 3, I visited with Rob Mason on the current state of UK regulations on messaging apps and where it may be headed.

Staying ahead of the curve when it comes to the shifting UK regulatory landscape is vital for financial institutions and their compliance professionals. Keeping pace with the FCA’s evolving priorities, as well as ensuring ongoing compliance with GDPR and data protection, can have significant effects on the smooth functioning of your institution. Enhancing operational resilience and implementing effective employee communication monitoring are essential steps to take, in addition to exploring resources for regulatory technology solutions. By remaining updated and flexible, compliance professionals in the UK can successfully navigate the complexities of regulatory changes, ultimately resulting in an improved understanding of current and upcoming UK regulations.

Here are some key steps:

  • Understand FCA’s evolving priorities and focus
  • Keep up-to-date with GDPR and data protection
  • Enhance operational resilience in your institution
  • Implement effective employee communication monitoring
  • Explore resources for regulatory technology solutions

 1. Understand FCA’s evolving priorities and focus.

Navigating the shifting UK regulatory landscape as a financial institution can be complex, but a key step is understanding the evolving priorities and focus of the Financial Conduct Authority (FCA). As the FCA shifts its focus towards a broader oversight approach, financial institutions must remain up-to-date with emerging regulations and adapt their internal processes accordingly. This comprehensive understanding of FCA priorities is vital for compliance professionals, as it enables them to mitigate potential risks, ensure data protection, and maintain operational resilience in an ever-changing regulatory environment.

Mason noted the FCA’s increased focus on retail and consumer financial services in addition to wholesale markets, which has led to a broader oversight approach and also highlighted the importance of data protection and the impact that GDPR regulations and Brexit have had on the UK’s regulatory environment.  Understanding the FCA’s evolving priorities and focus is crucial for compliance professionals in the UK, as it allows them to better adapt to the rapidly changing regulatory landscape. Being knowledgeable about current regulations and anticipating future changes can help institutions maintain compliance, safeguard data, and ensure operational resilience in the face of potential challenges. By staying informed and proactive, compliance professionals can successfully navigate the shifting UK regulatory landscape and contribute to the overall success and stability of their organizations.

 2. Keep up-to-date with GDPR and data protection.

With the ever-changing regulatory landscape in the UK, remaining up-to-date with GDPR and data protection is more crucial than ever for financial institutions. One of the significant changes that has come to focus in recent times is the GDPR, which greatly impacts how businesses collect, store, and process personal data. Data protection concerns have now begun to take center stage not only in Europe but also across the globe. By understanding the requirements of GDPR and other data protection laws, financial institutions can adapt to the changes and avoid costly fines or reputational damage.

Mason said that Europe has been ahead of the curve when it comes to data protection concerns, and how new developments, such as Brexit, have further emphasized the significance of GDPR in the UK. He also discussed how monitoring employee communications became increasingly critical for large organizations to prevent scandals. By keeping up with these regulatory changes and understanding the impact they have on organizations, compliance professionals can better equip themselves to face the challenges that lie ahead.  The importance of staying up-to-date with GDPR and data protection for compliance professionals in the UK cannot be understated.

These regulations help build a strong framework that ensures the protection of customer data, which is at the heart of any financial institution. Besides preventing financial and reputational damage, being compliant with GDPR and data protection laws allows organizations to maintain customer trust, demonstrate transparency, and ultimately contribute to the long-term success of their business. For financial institutions, being knowledgeable about these laws is not just a matter of regulatory compliance, but also a vital factor in creating a sustainable, ethical, and client-centric business. As the regulatory environment continues to evolve, staying ahead of the curve will prove indispensable for financial institutions and their compliance professionals.

 3. Enhance operational resilience in your institution.

In today’s rapidly changing regulatory environment, financial institutions must be agile and proactive in order to stay ahead of the curve. Enhancing operational resilience is a key step in achieving this goal, as it allows organizations to effectively manage unexpected disruptions and challenges. A strong operational resilience framework not only prevents potential losses but also helps maintain stability and reputation in the face of adversity. To successfully navigate the shifting UK regulatory landscape, financial institutions must invest in the necessary resources, infrastructure, and skill sets required for effective risk management, business continuity, and crisis response mechanisms. In this context, it is crucial for these institutions to regularly assess their resilience measures and adopt best practices in line with emerging industry trends and regulations.

Strengthening operational resilience safeguards the institution from potential losses and reputational damage, ensuring long-term success in a capricious regulatory landscape. Moreover, addressing operational risks effectively is crucial in mitigating negative consequences on a larger scale, preventing widespread financial contagion. As the UK financial sector undergoes constant transformation, compliance professionals must be equipped to adapt quickly to emerging challenges. By prioritizing operational resilience and staying abreast of the latest industry trends, these professionals will be better prepared to navigate the shifting UK regulatory landscape, protecting both their institutions and their clients from potential adverse effects.

As a compliance professional in the UK, it’s essential to keep up with the shifting regulatory landscape in order to ensure your financial institution can effectively overcome any obstacles. Staying informed about the FCA’s priorities, GDPR, and data protection regulations is key to maintaining a strong compliance strategy. Additionally, focus on enhancing operational resilience, monitoring employee communications, and seeking out resources for regtech solutions. By doing so, you’ll not only stay compliant but also foster a more secure and thriving financial institution.

Join me tomorrow where we review the recently released Global Relay report, Compliant Communications 2023.

For more information on Global Relay, click here.

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Compliance Into the Weeds

Compliance into the Weeds: What is Driving Compliance Engagement at the Board?

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

In this episode, co-hosts Tom Fox and Matt Kelly dissect the Navex 2023 State of Risk and Compliance Report. Tom and Matt delve into Navex’s annual benchmarking report, which surveyed 1,300 compliance professionals. The report revealed that 53% of respondents described their compliance programs as mature. Matt and Tom question whether the board is driving the conversation or if compliance officers request updates due to potential liability. The report’s findings on cybersecurity and privacy concerns, survey results on where compliance should reside in a company, and the importance of having a mature anti-bribery anti-corruption compliance program are all discussed. Tune in to hear more about how compliance officers can address pressing concerns such as cybersecurity breaches and attacks.

Key Highlights:

  • Navex’s benchmark report on compliance programs
  • Board-Compliance Officer Relationship & Cybersecurity in Compliance
  • The necessity of Dedicated Compliance Committees
  • Survey Finds Diverse Views on Compliance Placement in Companies
  • The Importance of Anti-Bribery Compliance for Cybersecurity
  • Compliance Officer Reporting to CISO Dynamics

 Resources:

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

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FCPA Compliance Report

FCPA Compliance Report – Maria D’Avanzo on Investigations

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Maria D’Avanzo from Traliant returns to discuss the essential role of outside counsel in FCPA investigations and the challenges that a CCO may face. They believe having trusted counsel with business acumen and commercial knowledge is vital, especially when discovering potential violations outside the initial scope of the investigation. Maria shares her experience working with the CEO and chair of the audit committee and offers excellent tips for compliance professionals learning to trust their gut. The speakers also discuss the importance of self-disclosure and equally applying disciplinary actions across different jurisdictions in misconduct cases. This explosive discussion is full of insights, advice, and best practices, making it a must-listen for anyone looking to improve their organization’s compliance standards. You won’t want to miss it!

Key Highlights:

  • Managing Whistleblower Complaints: Next Steps and Importance of Outside Counsel
  • FCPA Investigation Best Practices
  • Navigating investigations outside of the initial scope
  • Navigating Compliance Decision-Making
  • Internal Disciplinary Processes and Corporate Compliance
  • Supervised learning and DOJ cooperation challenges
  • The decision (or not) to self-disclose

Resources:

Maria D’Avanzo on LinkedIn

Traliant

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Great Women in Compliance

Great Women in Compliance – Mary’s Last Soliloquy

Join Mary Shirley, co-founder of The Great Women and Compliance podcast, as she reflects on the difficulties of finding the perfect guest for the show without it becoming a paid infomercial in her latest hosted episode. She also shares some fun behind-the-scenes information and announces her departure from the show. But don’t fret because the remaining episodes are packed with compelling discussions on self-awareness, promoting diversity and inclusion in the workplace, and implementing off-channel communication policies. You’ll gain valuable insights and tips from experts that will challenge your ideas and provoke your thinking. So don’t miss out; tune in now!

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network, where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights, where you can learn more about the podcast, stream prior episodes, and catch up on Mary’s monthly column, “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book, “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it, and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

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Daily Compliance News

Daily Compliance News: June 28, 2023 – The Forget the SEC Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition:

  • SBF loses bid to have criminal charges tossed. (Reuters)
  • Hertz Ex CEO wins clawback attack. (Law360)
  • Zambia police arrest former President’s son on corruption charges. (VOA)
  • Will ICRS become the global climate reporting standard? (WSJ)
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The Hill Country Podcast

Hill Country Podcast – Jane Ragsdale on Empowering Rural Guatemala

Welcome to the award-winning The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, Hill Country resident Tom Fox visits with the people and organizations that make this the unique area of Texas. Join Tom as he explores the people, places, and activities of the Texas Hill Country.

Join host Tom Fox in this exciting episode of The Hill Country Podcast as he speaks with Jane Ragsdale, the director of Heart O’ the Hills Summer Camp for Girls, who shares her inspiring story of how she started a tutoring program for underprivileged children in Guatemala City, eventually founding the non-profit organization “Guatemala Scholarships.” From there, the podcast turns to the struggles the people of Guatemala faced, including food insecurity and lack of access to basic amenities like electricity, running water, and healthcare.

Discover the heroic efforts of a group of volunteers from various denominations who travel to Guatemala to provide aid, including medical consultations, EMT kits, and basic healthcare and eye tests. Learn about their work in training people in first aid, CPR, and maternity assistance and their efforts to provide education in the area, including building a house for teachers and pre-k programs. Hear Jane’s inspiring story of building a retaining wall by hand in a village in Guatemala and how an organization called Let Hope Begin Here, Guatemala, is helping local students attend high school. Take advantage of this opportunity to open your Heart and learn about the real challenges facing communities in other parts of the world. Email Jane at jane@hohcamp.com or visit the website. Let hope begin here dot org to get involved! And stay tuned for a future conversation on running the camp with Jane.

 Key Highlights:

  • Jane Ragsdale: Journey to Mission Work
  • Falling in love with Guatemala and its people
  • Living conditions and healthcare in rural Guatemala
  • Fostering Healthcare in Rural Guatemala
  • Community-led construction and education efforts
  • Education and Tuition in Guatemala

Resources

Heart of the Hills

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program with Boards – Three Areas of Board Inquiry

Directors should focus on three core areas to help establish and maintain an effective compliance program: structure, culture, and risk management.

Structural questions. This area consists of questions that will aid in determining the fundamental sense of a company’s overall compliance program. The questions should begin with the basics of the program through to how the program operates in action.

Cultural questions. This area of inquiry should focus on the organization’s culture regarding compliance. Board members should understand what message senior management and middle management communicate. Equally important, the Board needs to understand what message is being heard at the lowest levels within the company.

Risk management questions. Board members need to understand the company’s process being used to identify emerging risks, their evaluation, and management. Such risk analysis would be broader than simply a compliance risk assessment and should be tied to other broader corporate matters.

Three key takeaways:

  1. A Board of Directors should inquire into the structural component of the compliance program as it will aid in determining the fundamental sense of a company’s overall compliance program.
  2. Cultural questions should be asked to understand what message is being communicated by senior and middle management.
  3. Risk management questions should be asked to understand the company’s process being used to identify emerging risks, their evaluation, and management.
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Innovation in Compliance

Messaging Compliance in a Shifting Regulatory Landscape: Part 2 – Is Business Innovation Being Stifled by Regulatory Actions?

Is messaging compliance giving your compliance function headaches? Welcome to a special 5 part podcast post series, messaging compliance in a shifting regulatory landscape, sponsored by Global Relay. Over this series, I will visit with Chip Jones, Executive Vice President – Compliance at Global Relay; Alex Viall, Chief Strategy Officer at Global Relay; Rob Mason, Director, Regulatory Intelligence at Global Relay; Jennifer Clarke, Head of Content at Global Relay; and Raewyn Danvers, Sales Manager, Unified Communications. Over this series, we will consider the US and UK regulatory framework for messaging apps, consider if business innovation is being stifled by regulatory action, preview the Global Relay Report: Compliant Communications in 2023, and look down the road on how to stay Ahead of regulation with the compliant communications in one app.

In this Part 2, I visit with Alex Viall UK regulatory compliance expert, to explore the intersection of regulation and innovation, and in this thought-provoking podcast as they discuss the dynamics between business innovation and regulatory compliance. Discover how the evolution of technology is causing a generational shift in communication and how this impacts businesses in the industry. Hear about the importance of capturing conversations and messages for law enforcement purposes and the need for policies and procedures to manage risks effectively.

Take advantage of expert insights on practical solutions, training, and monitoring policies to stay compliant. Learn why banning communication isn’t the answer and how a proactive attitude can lead to better risk management and regulatory compliance.

Key Highlights:

  • Balancing Innovation and Compliance in Messaging
  • Challenges of Ephemeral Messaging in Business
  • Communications Compliance and Training for Business Conversations
  • Overcoming the Ineffectiveness of Communication Bans

For more information, go to Global Relay.

Join us in our next episode, where we examine the current UK regulatory landscape for messaging apps.

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Innovation in Compliance

Supply Chain Cyber Risk Management with Steve Horvath

Imagine a world where your organization is constantly at the risk of a cyber-attack, yet no solution seems fully secure. In this episode of Innovation In Compliance, host Tom Fox and guest Steve Horvath explore the complex landscape of supply chain cyber risk management. They explore the high-profile breaches of Home Depot and Target, as well as the critical importance of frameworks like the NIST Cybersecurity Framework. Steve delves into the challenges faced by organizations, the need for effective risk management strategies, and the evolving landscape of cybersecurity in public and private sectors. 

Steve Horvath is a seasoned cybersecurity expert who has spent nearly two decades at Telos, a prominent cybersecurity firm focused on protecting government and industry networks. Since joining Telos in 2006, Steve has been instrumental in developing cybersecurity strategies and services for various elements of the U.S. federal government, including the intelligence community and the Department of Defense. Today, he leads the way in driving compliance and risk management initiatives with a focus on innovative solutions like Xacta.

 

You’ll hear Tom and Steve discuss:

  • Telos’ platform, Xacta, began as a web-based application focused on facilitating the rigorous compliance activities of federal standards, and has since evolved into a sophisticated platform for managing cybersecurity risks.
  • Cybersecurity risk is unique and highly challenging, and unlike other forms of risk, it doesn’t lend itself to transference. Insurance policies won’t save an organization from a devastating cyber attack.
  • Many organizations, particularly public ones, need to shift their mentality from accepting some level of risk to striving for robust cybersecurity operations that minimize risk as much as possible.
  • Education at the board level about the threats and implications of cybersecurity is a crucial yet often overlooked factor. The conversation around this is gaining traction, with initiatives such as the SEC’s rule about having a board member with a cybersecurity background.
  • The Home Depot and Target hacks brought widespread attention to cybersecurity risks, highlighting the need for organizations to be proactive in managing threats and vulnerabilities.
  • The NIST Cybersecurity Framework provides a practical and easily understood framework for organizations to assess and improve their cybersecurity posture. It enables effective communication between security operators and the board, fostering a common language and understanding.
  • Supply chain cybersecurity is a critical concern, particularly for software and IT hardware sourcing. Having a software bill of materials and understanding the ingredients within the software helps organizations assess their exposure and potential vulnerabilities.
  • Network attack services refer to understanding an organization’s attack surface and identifying potential points of ingress or exfiltration of data. Mitigating risks, such as phishing attacks, requires robust security education programs for users.
  • Creating an actionable cyber intelligence strategy involves having the right stakeholders and roles within the organization, selecting a suitable framework (such as NIST or ISO standards), and ensuring continuous validation and improvement of cybersecurity measures.

 

KEY QUOTES:

“You really have to do exceptional cybersecurity operations, and the best way to influence cybersecurity operations… is having some teeth behind a set of conditions and compliance requirements that guide you toward making the best decision…” – Steve Horvath

 

“The Risk Manager framework out of NIST [Cybersecurity Framework]… maps very easily and we find that it really allows for the security operators, the folks at the practical level doing the work. It gives them a language that they can articulate all the way up to the board and so everybody’s kind of speaking the same language.” – Steve Horvath

 

“A good security education program for your users tends to be a more dramatic impact than people realize. If you can teach your users not to click on links and emails or open documents, you’re way ahead of the gate.” – Steve Horvath

 

Resources:

Steve Horvath on LinkedIn | Twitter

Telos  | Telos Corporation on Twitter

Categories
Blog

Messaging Compliance in a Shifting Regulatory Landscape: Is Regulation Stifling Business Innovation?

Are you ready to learn how to implement electronic communications capture and supervision in your firm for better compliance and prevention of regulatory violations? Is messaging compliance giving your compliance function headaches? Welcome to a special 5 part blog post series on messaging compliance in a shifting regulatory landscape, sponsored by Global Relay. In this Part 2, I visited with Alex Viall on the provocative topic of where regulation stifles innovation in messaging apps.

The ever-increasing use of instant messaging in businesses brings about the need for compliant messaging policies. With proper guidelines, compliance officers and entrepreneurs can ensure that their company’s communication practices are up to par with regulatory standards and that potential risks are minimized. This enhances the overall efficiency and transparency of the business and provides peace of mind for those involved in managing and maintaining these communication platforms.

Here are some key steps:

  • Assess current communication platforms and habits
  • Create clear, transparent messaging policies
  • Implement regular employee training sessions
  • Monitor messaging compliance and address breaches
  • Explore tech solutions for messaging management

1. Assess current communication platforms and habits.

Developing compliant messaging policies for your business begins with assessing your company’s current communication platforms and habits. This critical first step involves thoroughly examining how employees communicate internally and externally and the tools and channels they utilize. You can effectively mitigate potential non-compliance issues by deeply understanding your business’s communication landscape. Identifying areas where innovation and improvements can be made while minimizing impacts on operations and employee experience is crucial. Therefore, it’s essential to keep an open mind and be prepared to adapt to the evolving nature of technology and ever-changing communication trends.

Viall underscored embracing business innovation while ensuring regulatory compliance and risk management. Communication habits constantly change, and organizations must adapt effectively while maintaining auditable trials for every conversation. Proper employee training is critical to fostering change and adopting new communication practices. This training should focus on creating comprehensive, practical policies that everyone can easily understand and adhere to, steering clear of generic policies that merely act as a checkbox.

Remember that senior management is pivotal in setting a positive tone and demonstrating a commitment to transparency and policy adherence.  Understanding and addressing the critical first step of assessing your business’s current communication platforms and habits is vital for compliance officers and entrepreneurs because doing so equips them with valuable insights into potential shortcomings, risks, and opportunities for growth. Organizations can proactively tackle potential compliance pitfalls by developing relevant and practical messaging policies while encouraging innovation and seamless communication. Ultimately, this will result in a more robust and resilient business that can effectively navigate the ever-evolving communication technology landscape and maintain a competitive edge in the market.

2. Create clear, transparent messaging policies.

Effective communication is essential for businesses today, and as technology evolves, so do the platforms and devices we use to communicate with one another. This shift in communication methods has increased the importance of creating clear, transparent messaging policies for companies. While internal and external communication may change, one thing remains constant: the need for proper risk management, regulatory compliance, and corporate hygiene. To achieve this, companies should develop comprehensive, practical policies for instant messaging that employees can easily understand and implement. The goal is to avoid creating generic policies that are simply a box-ticking exercise while supporting business innovation and maintaining auditable communication trails.

Viall noted that effective communication requires changing employees’ mindsets and ongoing training to ensure a secure and compliant messaging environment. Furthermore, senior management must set the right tone, reiterating the importance of compliance with these policies. Companies need to have procedures in place for monitoring, remediation, and promptly addressing any non-compliance issues. As technology continues to evolve, new tools and solutions for managing messaging compliance will become increasingly available, making it more important than ever for businesses to stay ahead of the curve.

Creating clear messaging policies cannot be overstated, particularly for compliance officers and entrepreneurs operating in an instant, ephemeral messaging age. With regulatory compliance and risk management at the forefront of business concerns, having practical, transparent policies can help ensure that a company maintains its competitive edge. This is especially true given the rapid advancements in technology and the potential consequences of non-compliance, which could lead to serious repercussions for businesses, both legally and financially. By focusing on transparent messaging policies, companies will be poised to manage risk effectively and thrive in today’s fast-paced, interconnected world of business communication.

3. Implement regular employee training sessions.

The nature of business is that it continues to evolve and adapt to new technologies, and communication methods are also changing. Gone are the days of only relying on traditional face-to-face conversations or even phone calls to get things done. With the rise of instant messaging platforms, companies now have a fast and effective way to communicate internally with team members and externally with clients. This new, dynamic form of conversation has greatly improved workplace efficiency and speed. Still, it also presents a significant challenge – ensuring that all communication is properly documented and compliant with various rules and regulations.

According to Viall, implementing regular employee training sessions is one crucial aspect of achieving this. These sessions should cover all of the proper procedures to be followed when using instant messaging in a professional setting and the potential risks and consequences of not adhering to these guidelines.  Conducting regular employee training sessions on messaging compliance helps create a company culture that prioritizes open communication, transparency, and, ultimately, accountability. When employees are knowledgeable and confident about what is expected of them, they are more likely to abide by the rules and demonstrate better judgment when faced with challenging situations. This reduces the likelihood of regulatory issues or scandals related to non-compliant messaging for businesses.

As compliance officers and entrepreneurs managing instant messaging in business, staying on top of evolving regulations and ensuring your company is adhering to best practices is crucial. You can significantly improve your organization’s regulatory compliance and risk by assessing your current communication platforms and habits, creating clear and transparent messaging policies, implementing regular employee training sessions, monitoring messaging compliance, and exploring tech solutions for messaging management. Do not hesitate to implement these steps and reap the benefits of a compliant and efficient messaging system.

Join me tomorrow as we consider changes in the UK regulatory schemes regarding messaging apps and compliance.

For more information, go to www.globalrelay.com