In partnership with
The FCA is building AI to watch your data, while the crypto gateway asks your firm to sign its own governance in writing
If you lead compliance, AI, or risk at a UK financial services firm, you are being asked to move faster and prove more at the same time. The FCA, that's the Financial Conduct Authority, the UK's main financial regulator, is now using AI to watch the market. Under SM&CR, the Senior Managers and Certification Regime, named individuals at your firm are personally accountable for what your systems do. This week the regulator showed how fast its own machines are getting, and opened a door that asks firms to prove their own governance in writing. One side of that gap is speeding up. The other is a signature.
Blu Dot surpasses 2,000% ROAS with self-serve CTV ads
Home furniture brand Blu Dot blew up on CTV with help from Roku Ads Manager. Here’s how:
After a test campaign reached 211,000 households and achieved 1,010% ROAS, the brand went all in to promote its annual sales event. It removed age and income constraints to expand reach and shifted budget to custom audiences and retargeting, where intent was strongest.
The results speak for themselves. As Blu Dot increased their investment by 10x, ROAS jumped to 2,308% and more page-view conversions surpassed 50,000.
“For CTV campaigns, Roku has been a top performer,” said Claire Folkestad, Paid Media Strategist, Blu Dot. “Comping to our other platforms, we have seen really strong ROAS… and highly efficient CPMs, lower than any other CTV partner we've worked with.”
Using Roku Ads Manager, the campaign moved from a pilot to a permanent performance engine for the brand.
What's moving this week
The FCA's "first responder" is an AI, and it processes a billion rows a day
On 22 September, FCA Chief Executive Nikhil Rathi told a TheCityUK dinner that the regulator is "exploring agentic AI as our 'first responder' to speed up how we monitor wholesale markets." The text was published on 23 September. He said the FCA processes "a billion rows of data per day" and will pair AI with supervisory judgement to combat market abuse faster. The same speech committed the FCA to consult on safeguarding rules for relevant tokenised investment assets, and to publish a joint tokenisation roadmap with the Bank of England, with no date given.
The direct audience is wholesale: exchanges, trading venues, market infrastructure providers, banks and asset managers active in tokenised assets or subject to market abuse surveillance. The wider signal reaches every supervised firm. Rathi also reported "pilot fatigue" among firms and a demand to move "from experimentation and sandboxes, towards full production and permanence." The FCA cited the first fully native tokenised fund it authorised in June and the approval of HSBC Orion's digital securities depository services.
The AI governance implication is a reversal of the usual question. If the regulator's own machine spots a pattern in your trading or reporting before your compliance function does, the first question to you will not be about the model. It will be about the human. Under SM&CR, a named senior manager must show reasonable steps were taken, which means someone owns the surveillance output, reviewed the alerts, and recorded what they decided. A firm running its own agentic tooling without that review trail is already behind a regulator that has one.
The crypto gateway is open, and the application is an attestation
On 30 September, the FCA opened its cryptoasset authorisation gateway. Firms can now apply for FSMA authorisation for the newly regulated activities, including trading platforms, dealing, safeguarding, staking and issuing stablecoins. Applications close on 28 February 2027 and the full regime takes effect on 25 October 2027. FCA Director of Authorisation Dominic Cashman said: "The UK's new crypto regime will give consumers greater protections and firms a clear framework to operate in." Applicants must show they meet standards on consumer protection, asset safeguarding, market integrity and financial resilience.
This affects existing crypto firms, which, as covered in Edition 30, cannot rely on Money Laundering Regulations registration converting automatically. Firms that apply in the window can keep operating while the FCA assesses them, and those who miss it risk losing that protection. Handbook Notice 144 adds a second route in. From 28 September, UCITS schemes and non-UCITS retail schemes may hold cryptoasset exchange-traded notes up to 10% of scheme property, which pulls authorised fund managers into crypto exposure for the first time.
The AI governance implication sits in the drafting. Many applicants will use AI tools to draft answers and map controls against the four standards. That is reasonable, but the application is a written statement signed by accountable people. A named senior manager who signs a safeguarding or financial resilience statement an AI tool produced, without a recorded check, has attested to something they cannot defend. Fund managers adding crypto ETNs face the same test on due diligence: who approved it, and what did the AI-assisted screening actually say?
Some teams never seem to stop moving. They're on Attio, the agentic CRM.
It’s your always-on revenue engine: agents and workflows build pipeline, chase every buying signal, and move deals forward alongside your team.
Teams like Parallel, Turbopuffer, and Wordsmith build on Attio. Are you one of them?
The BuildMoat angle
This week's two stories describe one gap from opposite ends. The regulator is automating its own attention, and firms are automating their own paperwork. In both cases accountability still lands on a person with a name. AI adoption failure in regulated environments is a human infrastructure problem: the missing chain from a model's output to a named human decision, with a record of what that human checked. A Head of Compliance or Head of AI should do one unglamorous thing now. Pick the three AI-assisted processes that feed regulatory statements or surveillance, name the owner of each, write down what that owner checks, and keep the record before someone else asks to see it.
One question to take into next week
Pick any regulatory statement your firm made in the last 90 days that an AI tool helped draft or review. Can the named senior manager show you what they checked before they signed?
If this is a live problem in your organisation, reply to this email. BuildMoat works with UK financial services firms to build the human infrastructure that closes the gap between AI deployment and regulatory accountability.
BuildMoat — buildmoat.co.uk
Thanks for reading
That's it for this week. If something landed, reply and tell me. If something was wrong, reply and tell me that too. I read every response.
Forward this to one person who should be reading it.
For sponsorship enquiries, email [email protected]
Regulatory commentary is for informational purposes only and does not constitute legal, compliance, or financial advice. Consult a qualified professional for advice specific to your firm. BuildMoat product mentions are editorially assessed and disclosed where a conflict exists.
Until next week.
