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Governance that survives an examination, not a binder nobody reads.

For a regulated firm, the bar is conservative AI governance that holds up when an auditor or an examiner asks how you control it. That means a policy, an approved-tools list, a certification, and training, all keyed to a data classification built around authorization.

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GREEN / YELLOW / RED
data classification keyed to authorization, not just document type
Examination
the bar we design to, not just internal policy
20 min
the training that staff will actually follow, not a 40-page binder

Most AI policies are written for a document type. The risk is in the authorization.

A generic AI policy sorts data by what kind of document it is. That is not enough for a regulated or litigation-exposed firm, because the same kind of document can carry very different obligations depending on whether a protective order, a court order, or a client commitment governs it. A policy that ignores that distinction will not hold up when it matters.

Our GREEN, YELLOW, RED classification is keyed to authorization. The tiers are built around the data that actually raises the stakes, MNPI, privileged material, protected client records, and the policy tells your team, and an auditor, exactly which AI tools can touch which material and why. That is the difference between a policy that looks complete and one that actually is.

Watch the classification work on real text
What an AI governance engagement delivers

A policy people are trained on and follow, not filed and forgotten.

Four parts that work together, sized to your firm.

A policy keyed to authorization

A self-contained AI acceptable-use policy built around a GREEN, YELLOW, RED classification that asks not just what a document is, but whether a protective order, a court order, or a client commitment governs it.

An approved-tools list

A clear list of which AI tools are permitted for which classes of data, with tightly scoped permissions and features disabled or restricted where compliance risk outweighs convenience.

Certification and training

An employee certification and a staff training program that make the policy something people understand and follow, not a document filed away and forgotten.

Audit and examination readiness

Governance designed with compliance and legal from the start, so it answers the questions a SOC 2 auditor or a regulatory examiner will actually ask.

What the one-pager looks like

The acceptable-use policy fits on one page.

The acceptable-use deliverable is a single page your staff can actually follow. This is the shape of it.

Acceptable use of AI, on one pageIllustrative excerpt

GREEN. Material with no client identity and no confidentiality obligation attached. Approved tools may be used without extra sign-off.

YELLOW. Client-related material not governed by an order or a commitment. Approved tools only, and a person reviews the output before it reaches a client or a record.

RED. MNPI, privileged material, protected client records, or anything governed by a protective order, a court order, or a client commitment. It does not enter an AI tool.

Approved tools. Only the tools on the approved list, configured by the firm. Nothing else touches client material.

Human review. AI drafts, a person decides. Work that carries risk gets a human sign-off before it leaves the firm.

When unsure. Treat it as RED and ask first. The policy names who to ask.

Illustrative excerpt. Your policy is co-developed with your leadership and keyed to your obligations.

In practice

AI governance for an SEC-registered investment adviser

For a regulated adviser, we established conservative AI governance designed to survive examination: tightly scoped tool permissions, the GREEN, YELLOW, RED classification, and AI features disabled or restricted where compliance risk outweighed convenience.

Those patterns are now reused across other regulated clients. The governance is paired with the infrastructure, so the policy is not aspirational. It matches what the firm can actually do.

Need governance that holds up under scrutiny?

A short call is enough to tell you where your current AI governance has gaps and what a right-sized program would cover for your firm.

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AI Readiness Checklist

The questions every regulated firm should answer before adopting AI

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The Regulated Firm's AI Readiness Checklist

Six questions that decide whether your firm can adopt AI without putting client data, a renewal, or an examination at risk. Walk them before your next audit, not after.

  • Where client data is leaving your environment through personal AI accounts
  • Whether your AI controls would survive a SOC 2 audit or an examination
  • Where a human, not the model, needs to ratify the output

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Common questions about AI governance

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