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A few months ago, BuildMoat's focus was broad. AI adoption, behaviour change, human infrastructure. All of it true, all of it still relevant. But something kept coming up in every conversation I had with people inside financial services firms.
They weren't struggling to find AI tools. They were struggling to explain to anyone - internally or externally, who was accountable for what the tools were doing.
That is a compliance problem. And in UK financial services, it is also a regulatory problem with a name: SM&CR. The Senior Managers and Certification Regime exists precisely to ensure that named individuals can be held accountable for what happens inside their firms. As AI moves into more and more regulated workflows, that accountability structure has not kept pace with the technology. The gap between what firms have deployed and what they can demonstrate to a regulator is real, it is growing, and the FCA is running out of patience with firms that treat it as someone else's problem.
This newsletter exists because of that gap.
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What you will read here every Friday
Each edition covers the regulatory developments that matter most to compliance leads, heads of AI, and risk directors in UK financial services. Not everything that moved that week, only the things that change what your firm should be doing.
The seven areas I will be watching consistently:
SM&CR and accountability: how personal liability is evolving as AI moves into regulated workflows, and what named senior managers need to demonstrate to stay on the right side of enforcement.
AI governance and the EU AI Act: the FCA's principles-based approach is not a free pass. This covers the Mills Review, accountability guidance, audit trail expectations, and how the EU AI Act creates parallel obligations for firms with European exposure.
Consumer Duty: enforcement is accelerating. Board reporting standards, vulnerable customer obligations, and the application of the Duty to AI-assisted products and services.
FCA enforcement and supervision: fines, Dear CEO letters, thematic reviews, and supervisory signals. What the FCA is actually doing, not just saying.
Operational resilience: Critical Third Parties, DORA, incident reporting, outsourcing risk, and what the designation of AI and cloud providers as CTPs means for your risk framework.
Capital markets reform: consolidated tape, revised transparency and transaction reporting frameworks, and the tailored MiFID-style rules being built for UK markets post-Brexit.
Cryptoassets and digital finance: the authorisation gateway opens in September 2026. Regime goes live October 2027. The firms that are not ready will not get a grace period.
Not every pillar appears every week. When something moves, it leads the edition. When nothing moves, it waits. What you will never get here is padding.
What we have built because of all of this
The newsletter is also the context for something BuildMoat has been developing quietly over the past few months: the AI Compliance Co-Pilot.
This is not a product we invented in a boardroom. It is the direct result of what I kept hearing in the field - compliance teams that knew they had a problem but had no structured way to address it, and no managed service that sat at the intersection of AI governance and SM&CR accountability.
The Co-Pilot is a hybrid human-AI managed service. It monitors regulatory developments, maps them to your firm's AI-assisted workflows, flags accountability gaps, and produces the documented oversight trail that a named senior manager needs to demonstrate they are in control. The human review layer is not an add-on. It is the point. Because what regulators want is not an algorithm that claims to be compliant. They want a person who can show their working.
If you are reading this, you are probably already living some version of this problem. That is why I built it. And it is why this newsletter exists — not to sell you something first, but to make sure you are never caught off guard by what is coming.
Edition 01 lands this Friday
The first full edition covers what is moving right now: the cryptoasset authorisation timeline, the SM&CR AI accountability clarification driven by the Treasury Committee, and what both mean for firms that already have AI tools running inside regulated workflows.
If this is relevant to someone in your network, forward it. The people who need this most are the ones who do not yet know they need it.
Emeka
Founder, BuildMoat