Artificial intelligence

AI Governance Review

The Financial Conduct Authority’s expectations have been made clear from several FCA publications:

The FCA have no plan for an AI rulebook. Instead, the UK regulator simply points to existing obligations under SYSC, MAR, SM&CR, Consumer Duty, operational resilience etc.

This supervisory approach is not restricted to the UK of course. Across the EU, firms must overlay the AI Act on top of current financial-services and data-protection requirements. In the US, AI is expected to be managed through the same compliance, supervision and disclosure structures that already apply to SEC-registered firms.

What regulators expect in practice

All about some AI policies right?  No, look at the FCA’s carefully crafted language – it’s much more about good governance.

Regulatory expectations are converging around governance, accountability, and demonstrable control.

Firms are expected to evidence:

  • A clear and documented understanding of where AI is being used and by whom 
  • Defined ownership and accountability under SM&CR 
  • Appropriate controls and oversight 
  • Effective management of third-party risk 
  • Documentation and audit trails that demonstrate governance in practice 
  • Evidence that controls are operating effectively, supported by monitoring, testing, and management information
AI is already active in your business. The risk is the same at many regulated firms that cannot evidence how AI is currently in use nor, in practice, how it is being governed.

The Current AI Governance Challenge

The challenge firms face today is not theoretical. Across the industry, we see two structural gaps already in existence:

  • The Capability gap. Oversight functions often lack the tools and understanding to govern AI effectively.
  • The Implementation gap. There is no clear, consistent method to translate regulatory expectations into operational AI governance.

The core challenge firms now face in practice is how to consistently implement AI governance via tailored AI polices, acceptable use standards, AI risk assessments and ultimately, effective oversight frameworks. 

Most firms are currently trying to solve this problem on their own due to a lack of direct rule making. If these gaps are not addressed, they become regulatory, operational, and reputational risks.

What we’re seeing in practice

Across regulated firms, we consistently see:

AI Governance

The AI Governance Reality

AI is already being used across firms in compliance, operations, and decision-making, often without formal governance or oversight and most commonly via staff personal accounts and access. The risk is that AI governance has not kept pace with development and deployment.

In practice, firms often lack a clear view of:

  • what AI tools and models are being used and by whom?
  • what they are being used for and what data is being used? 
  • how they are being controlled, if at all? 
  • who is accountable for oversight? 

Industry research consistently shows that firms are deploying AI faster than they can govern it. The challenge is no longer whether to use AI, it is whether firms can demonstrate and evidence how its use is being governed. This is where most firms need a structured, proportionate approach to AI governance. Blueprint GRC can help.

Regulators are increasingly clear on this point, as evidenced in the FCA’s periodic, “Regulatory Priorities”, publications.  In the UK, whilst there are no AI-specific rules yet, existing obligations apply in full, including under SYSC, MAR, SM&CR, and the Consumer Duty. 

Firms remain fully accountable for outcomes, regardless of whether they are AI-driven.

Blueprint GRC’s Independent AI Governance Review

We offer an inexpensive impartial review of your AI governance arrangements, comparing your internal controls to those expected by the regulator and those being used by your peers. The output is an actionable report to be used internally, or to be used to evidence to stakeholders, including regulators, that your AI governance has been independently assessed and meets good governance objectives.

We review and report on whether AI governance is truly operational, and not merely theoretical. We want to see the capability and implementation gaps have been addressed.

Our approach is simple:

  • Clarity over complexity 
  • Implementation over theory 
  • Evidence over policy 
  • Monitoring over assumption

We help establish control over AI usage, apply risk-based governance and oversight and evidence processes proportionate to how the technology is being used.

This ensures governance is proportionate, practical, and defensible in practice.

The objective is not to create a theoretical AI policy. It is to help firms translate high-level obligations into day-to-day operational governance that works across the Three Lines of Defence

Blueprint GRC offers a structured, practical approach to governing AI in real-world environments.  Our AI Governance Review creates a framework for good governance and is structured around four core components:

AI Control Framework

  • AI Policy 
  • Acceptable Use Standard 

AI Use Case Lifecycle

  • Governance process and approval model 

AI Assessment & Risk Framework

  • Know Your Needs assessment 
  • Model / architecture assessment 
  • AI risk assessment

AI Oversight & Monitoring

  • Vendor due diligence 
  • AI use case register 
  • AI monitoring framework
  • Governance reporting

What good looks like

A well-governed approach to AI includes:

  • Clear restrictions on AI use, including controls over data input and approved tools 
  • A complete inventory of AI use across the firm – at firm and employee level 
  • Defined ownership and SM&CR accountability 
  • A risk-tiered approach to assessing AI use 
  • Structured oversight of third-party tools 
  • Ongoing monitoring and oversight, including use case-level control validation, periodic review, and clear management information
  • Documentation that can be relied upon in practice 
  • Documentation, reporting, and management information designed to evidence how AI governance operates in practice, supporting regulatory and investor scrutiny
  • An independent assurance model that is proportionate to the firm, whether through in-house internal audit or a properly structured outsourced arrangement

AI Governance – Self Test

Ask yourself…
If you are unable to answer positively to these high-level questions, you probably already have a governance gap, whether it has been identified or not. Remember, regulated firms are not being asked whether they use AI, that is assumed (even if only at employee personal use level), they are being asked to demonstrate how it is governed.

AI Governance framework:

A practical, proportionate framework for implementing AI governance

Overview

AI is already being used across firms often without clear oversight, ownership, or documentation. While adoption has accelerated, governance has not kept pace.

Across the industry, firms are facing two structural challenges:

  • A capability gap – oversight functions lack the tools and understanding to govern AI effectively 
  • An implementation gap – there is no clear, consistent way to translate regulatory expectations into operational AI governance 

This creates a disconnect between how AI is being used and how it is governed.

The Financial Conduct Authority’s position is clear and reflects a broader global direction: existing obligations including under the Principles for Business, SYSC, SM&CR, and the Consumer Duty apply in full to AI.

Firms are not being asked whether they use AI. They are being asked to demonstrate how it is governed.

What the framework is designed to do

Our Framework helps firms:

  • Identify and document how AI is being used across the business 
  • Establish clear ownership and accountability 
  • Assess and manage risks associated with AI use 
  • Align AI use with existing regulatory obligations (including SYSC, MAR, SM&CR, and the Consumer Duty in the UK) 
  • Implement appropriate controls and oversight 
  • Establish clear controls and standards governing how AI can and cannot be used
  • Monitor AI use and outputs over time 
  • Produce evidence that can be relied upon by regulators and investors

AI Governance – Core components of the framework approach

AI Use Case Register

A central inventory capturing where and how AI is used across the firm, including ownership, purpose, and data inputs.

Risk Assessment Framework

A proportionate, risk-tiered approach to assessing AI use cases, allowing firms to focus effort where it matters most.

AI Policy & Acceptable Use

A clear, practical policy framework aligned to how AI is actually being used within the firm. This sets out how AI can and cannot be used, including expectations around data handling, acceptable use, and oversight.

Vendor Due Diligence

Structured assessment of third-party AI providers, including data handling, security, model governance, change management, and jurisdictional considerations.

Governance & Approval Process

Defined ownership, accountability, and approval workflows to ensure appropriate oversight of AI use.

Monitoring & Oversight Framework

Structured monitoring of AI use at the use case level, including control validation, Use Case Owner attestations, compliance sampling, and management information reporting.

Governance & Evidence Pack

Documentation, reporting, and management information designed to evidence how AI governance operates in practice, supporting regulatory and investor scrutiny.

Our framework is:

  • Proportionate – scaled to the size and risk profile of the firm 
  • Practical – designed for lean compliance and operational teams 
  • Regulator-aligned – grounded in FCA expectations and consistent with global direction 
  • Evidence-driven – built to stand up to regulatory and investor scrutiny 

The result is a framework that can be implemented, operated, verified, and evidenced, not just documented as a disparate set of policies weak under FCA scrutiny.

Ongoing Oversight Service

Rarely do regulatory expectations fit into a ‘one and done’ approach, nor do the underlying factors ever stand still. AI Governance is no exception and consequently we offer an ongoing level of support.

Retained solution

Continued access to subject-matter experts.

Market and regulatory updates

Proactive input from external developments.

Periodic reviews

Revisiting your AI Governance framework to consider internal changes and external influences.

Management and information reporting

Create periodic reporting to evidence management engagement.

AI Data Governance

Fragmented data equals friction

Disparate or inconsistent data can result in:

  • Excessive reconciliation cycles
  • Delayed or inaccurate reporting
  • Slower decisions
  • Missed opportunities.

When data is fragmented, decisions are slow and may be poor. Hours spent on scrubbing and reconciliation could be used more efficiently. The foundation matters – get the data right first.

Deploying AI?
Start with Authority

Strong AI begins with stronger data foundations.

Divergent data risks the integrity and success of any AI implementation — getting to the master source or single truth is vital.

The hidden cost of data chaos

Data errors remain one of the top challenges for investment managers

  • Teams waste significant time on data reconciliation
  • Most firms lack centralized data discovery
  • Decisions made on stale data in real-time markets
  • Different teams working from different versions of truth
  • Critical reports delayed because data “doesn’t match”
  • Hours wasted on firefighting, not alpha generation
  • Manual processes that don’t scale with AUM growth
  • AI and internal systems producing inconsistent outputs

Confidence in your numbers is non-negotiable.

Analytics · Alpha · AI

All powered
by Trusted Data

What We Deliver

Precision-engineered data foundations that transform chaos into confidence

  • Eliminate reconciliation bottlenecks
  • Accelerate reporting from days to hours
  • Strengthen trust in NAV and risk analytics
How We Transform Your Data

Seamless Integration: Unify all data sources into one analytics layer

Advanced Aggregation: Synthesize across funds without losing granularity

Actionable Analytics: Data structured for investment decisions

Built for Confidence and Scale

Quality Controls: Catch errors at source, not month-end

Future-Proof Models: Flexible data models that evolve with your business without costly system overhauls

End-to-End Governance: GDPR-compliant with full audit trails

The Blueprint GRC Advantage

While competitors wrestle with Excel chaos, you could be making decisions on real-time trusted data. Turn data into your competitive advantage.

Domain Expertise: We speak NAV, attribution, compliance – not just tech

Cost-Optimized: Enterprise capabilities without enterprise overhead

Proven: From boutique managers to global platforms

Ready to Build Trust in Your Data?
  • Optimise fast accurate data for investment decisions
  • Augment disparate data for regulatory reporting
  • Reduce, maybe remove complex and time-consuming reconciliations
  • Clean data before use, reduce false positives, improve data-governance
  • Gain confidence in accuracy of AI output

If data is unified, performance accelerates. Let’s transform your data infrastructure into a decision engine.

Who this is for

Get in touch

If you would like independent support to help ensure your AI Governance stands up to scrutiny, we would be happy to walk you through our approach.