Following a sweep investigation, financial regulators recently unveiled a string of settlements with large institutions arising out of employees' use of unauthorized or "off-channel" applications such as WhatsApp for business-related communications. The sweep was widely publicized, and at a high level, the resulting charges are not necessarily surprising. However, a closer look at the settlements reveals some takeaways regarding the regulators' approach to resolving multiple cases with similar issues, and that approach appears to be largely one-size-fits-all, with limited transparency.