- Essays··14 min read
Sunday Essay — The Case File and the Second Pair of Eyes
ABN AMRO's €180 million disgorgement in 2021 was calculated from the compliance staff the bank had not hired — a price set on a missing second pair of eyes. Its October 2026 agent pilot raises the same question: when software builds a case file, who checks it? The answer requires both an architecture that separates inferences from direct reads and a live measurement — seeded defective files, counted per queue — to prove the control is real.
financial-crimeamlagentic-aifour-eyes-principleRead - Essays··8 min read
Singapore Checks Who Pays for the Ad
Singapore's ad-verification reforms—requiring platforms to check who is paying for an ad, not just who appears in it—represent the correct control point against scam advertising, but one that arrives late. The shift from face-recognition filters to advertiser identity checks matters because evasion of the latter costs something per account; evasion of the former costs nothing. The open question is whether scam spend will simply re-aim at jurisdictions where the buying desk still asks nothing.
singaporedigital-advertisingplatform-regulationad-verificationRead - Essays··7 min read
The Agentic AI Gap: SR 11-7 Is Dead, the EU AI Act Is Late, and Banks Are Shipping Agents Anyway
Three jurisdictions, zero frameworks designed for the agents already in production. The governance gap between SR 26-2's carve-out, the EU's sixteen-month delay, and the UK's 'further work' is where the first enforcement action will land.
agentic-aimodel-risk-managementeu-ai-actbanking-regulationRead