Every customer message needs a record. Every decision needs a name.
Banks, lenders and payments firms already run AI at scale — Consumer Duty and SM&CR expect you to know what each use case does, what data it sees, and who is accountable.
of UK financial firms use AI; the median firm runs nine use cases (Bank of England/FCA, 2024)
only partly understand the AI they use (Bank of England/FCA, 2024)
use cases are third-party implementations (Bank of England/FCA, 2024)
Accountability stays with a named person.
PRA SS1/23 (April 2026): model risk, including AI and vendor models, sits with a named Senior Management Function holder. The Treasury Committee has asked the FCA for guidance on Consumer Duty and AI, and for clear accountability frameworks for AI-caused harm, by the end of 2026.
Regulator statements summarised from the published guidance; see the sources on the Problems page. This supports compliance; it is not legal advice.
- Customer communications and collections letters
- Complaints handling and triage
- KYC, onboarding and fraud checks
- Credit and affordability analysis (decision support, not decisions)
- Automated decisions without a documented human check
- Customer data in unmanaged tools
- Third-party AI features nobody has assessed
Gateway and Ledger on every customer-facing AI. Comms with a compliance pass and category-based sign-off. Contact on Amazon Connect with 100% monitoring. Rules that names where AI must not decide. Evidence Packs for the regulator.
Four agents, trained for this sector.
The rules, as controls.
- FCA Consumer Duty
- PRA SS1/23 model risk (Apr 2026)
- CONC and DISP
- SM&CR
- Money Laundering Regulations 2017
- UK GDPR and DUAA
Issues detected · needs attention first
| Issue | Rule | Severity | Owner | Status |
|---|---|---|---|---|
| Payroll file uploaded to an external AI tool | R-15 | High | HR Director | Blocked · reviewed |
| 31 personal AI accounts found in Sales | R-02 | High | Head of Sales | Migrating · 27 done |
| Customer data in a prompt without redaction | R-01 | High | Ops lead | Redacted · 0 left |
| Premium model used for internal drafts · 412 requests | R-07 | Medium | Engineering lead | Rerouted |
| CRM "AI assist" running without a DPIA | Policy | Medium | Head of Sales | DPIA in progress |
| Agent attempted an external email | R-12 | Low | S. Reid | Held · approved |
| Job | Owner | RAG | Effort | Cost to date | Forecast | Actual | Variance | Return / yr | Status |
|---|---|---|---|---|---|---|---|---|---|
| Migrate personal accounts to managed | IT Director | 12 d | £4,200 | £6,000 · 20 d | £4,200 · 12 d | −£1,800 · −8 d | risk | Done | |
| Route everyday tasks to standard tier | FD | 3 d | £900 | £1,200 · 4 d | £900 · 3 d | −£300 · −1 d | £58,400 | Done | |
| Payroll upload block (R-15) | HR Director | 1 d | £300 | £300 · 1 d | £300 · 1 d | 0 | risk | Done | |
| Collections letters via Comms agent | Head of Collections | 18 d | £11,600 | £14,000 · 25 d | — | on track | £96,000 | In progress | |
| KYC document checks | Head of Onboarding | 9 d | £5,100 | £9,000 · 15 d | — | on track | £61,000 | In progress | |
| Contact-centre adviser assist | Head of CS | 26 d | £19,800 | £16,000 · 20 d | — | +£3,800 · +6 d | £142,000 | At risk · vendor delay |
Effort, cost and return are recorded against each job as it happens. Done means the job is solved in production with its owner’s sign-off, not that a licence was bought.
From this sector.
Do you understand Consumer Duty?
Our founders ran FCA-regulated lenders and a bank's technology under it. The Comms agent's compliance pass was designed around it.
Will the FCA accept AI-drafted communications?
The FCA regulates outcomes, not tools. What it expects is that you can show the checks, the sign-off and the record. The ledger is that record.
Where does our data go?
Nowhere new. Everything runs inside your own cloud account. Nothing routes through GenWA's infrastructure. Sensitive data is removed before a request leaves your environment.
Find out where your AI stands. Then decide.
Under a minute, an upload, or a visit. Something for the board either way.