- 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
The Underwriter Reads Second
The safest AI architecture in insurance underwriting does not let the model decide — it lets the model read. Across every serious deployment in Japan and Korea in 2026, the machine extracts, classifies, and routes; a named underwriter signs the outcome. Japan's FSA and Korea's FSC arrived at this split from different premises — explainability on one side, fraud containment on the other — and reached the same architectural conclusion.
insurance-aiunderwritinghuman-in-the-loopfinancial-regulationRead - Essays··10 min read
What Can You Actually Test
The FCA's August 2025 review of algorithmic trading controls at ten principal firms found significant variation in compliance sophistication — but the structural problem is older than the review. Attestation requires a compliance officer to certify what an algorithm does when she cannot read the code, testing covers yesterday's scenarios, and surveillance measures what someone thought to calibrate. The FCA has named the gap; the attestation merely documents that the firm knows it exists.
algorithmic-tradingfinancial-regulationcompliancemarket-surveillanceRead - Essays··11 min read
The agentic AI carve-out: why US and EU regulators are writing rules neither can enforce
The Federal Reserve placed agentic AI outside its model-risk framework in April; the European Commission issued transparency guidance two weeks before enforcement began in August. For banks operating across both jurisdictions, the collision is immediate and the governance gap is real. The first regulatory action will likely come for failing to document why deployment was safe at all, rather than for deploying these systems badly.
agentic-aifinancial-regulationmodel-riskeu-ai-actRead - Essays··11 min read
Sunday Essay · Singapore's Rulebook for Agentic Finance
Singapore's Monetary Authority has published the first regulator-authored document to name, at runtime, the exact control gates between an autonomous agent's proposed action and a live ledger. SAFR's policy engine, runtime validator and append-only audit ledger map onto what DBS and Grab Finance already run in production. For model risk officers from Jakarta to Frankfurt, this is the document to read before the vendor decks arrive.
agentic-aifinancial-regulationmodel-riskmas-singaporeRead