Hi there,
Welcome to The Accountability Record. This is a newsletter for the people personally named under SM&CR: the Senior Managers, compliance leads and risk owners who carry individual accountability for what AI does inside a regulated firm.
Last week I shared the Obligation Map - a crosswalk that translates an SMF holder's Statement of Responsibilities into concrete, AI-activity-level duties, so nothing sits in the gap between "my responsibilities" and "what this system actually does."
This week I am giving away the Regulatory Intelligence Digest - a plain-English feed of what the FCA and PRA are saying about AI, written for the person personally on the hook rather than for the firm. Most firms have the governance. Very few have the individual evidence. And the regulator's own guidance on what that evidence should look like is not due until the end of the year, but we have to stand-in with the evidence to demonstrate continuous oversight in the meantime.
BuildMoat builds the engine that produces and maintains these records across every AI system in a firm. Putting the tools in your hands, one at a time, is how we show you the problem is real and the approach works. If the hand-tools are all you ever need, keep them with our compliments. If your AI estate is bigger than a handful of systems, you will know where to find us.
What you're getting
The final free artefact in this series is the Regulatory Intelligence Digest: a plain-English read of what the FCA, PRA and Bank of England are saying about AI, written for the person personally on the hook rather than for the firm. Free, and it keeps coming.
Why it matters
Every other artefact in this series is a record you complete. This one keeps those records current. The reasonable-steps bar is not fixed. It moves every time the FCA publishes a speech, a Dear CEO letter, or the good and poor practice guidance still due later this year. A certificate or oversight pack built to last year's expectations is a liability dressed as evidence.
Most compliance updates are written for the institution. The named individual is left to work out for themselves what a development means for their personal exposure. That translation is what the Digest does: the development, what it changes about individual accountability specifically, and the one thing a Senior Manager might do about it this month.
The series, and what runs it
That is the whole series: five artefacts, each closing a different part of the evidence chain, all free. Held by hand, they are a strong start. Held across every AI system in a firm, kept current, and stored as hashed, tamper-evident records, they stop being documents and become a system. That system is what BuildMoat runs, around the clock. The artefacts show you what good looks like. The engine is how you hold it, everywhere, all the time.
→ [Regulatory Intelligence Digest] — free, and it does not stop.
That is the series.
Five artefacts, each closing a different part of the same problem: proving, in writing and on time, that a named person oversaw the AI in their care. Take all of them, use the ones that fit, and pass them to whoever on your team carries the same weight. The accountability was never going to wait for the guidance, and now you have something to stand on while it arrives. We will keep the Digest coming, because the bar keeps moving and staying current is the one part of this that never finishes. And if the day comes when doing all of this by hand, across every system, every quarter, stops being realistic, you will know where to find us. Until then, thank you for reading, and for taking the work seriously. That is the whole reason it exists.
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.
