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 Emergent Event Protocol - the pre-agreed playbook for when an AI system does something unforeseen, defining who is accountable, what gets recorded, and what "reasonable steps" looked like before the surprise, not after.
This week I am giving away 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." 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 this week
This week's free artefact is the Obligation Map: the crosswalk that translates a Senior Manager's Statement of Responsibilities into concrete, AI-activity-level duties, so nothing sits in the gap between what you are responsible for and what your systems actually do. Free, and usable today.
Why it matters
The FCA has been clear it will not create a dedicated AI Senior Management Function. Responsibility for AI sits inside your existing Statement of Responsibilities. That sounds tidy until you try to draw the line from a paragraph written in regime language to a model written in technical language. Nobody owns that translation, and the untranslated space is exactly where accountability falls through: the activity no one's responsibilities quite cover, discovered only when it goes wrong.
What it does
The Map puts your responsibility limbs down one axis and your firm's AI activities down the other, and forces the question for each: which duty covers this, and who holds it. The most valuable cells are the empty ones, the activities no named individual currently owns. Far better to find those on a page now than in a supervisory review later.
Mapping a live, changing estate is not a one-time diagram. As systems and responsibilities shift, the gaps move with them. BuildMoat's engine keeps the map current and the coverage honest, continuously. The artefact shows you the method. The engine keeps it true.
→ [Download the Obligation Map]— free, run it against your own responsibilities today.
Next week, the last in the series: the Regulatory Intelligence Digest, the one that keeps everything else current.
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.
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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.
