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AI Governance

Built for Governed AI

The Four Eyes Financial client compliance lifecycle platform is built for governed AI. AI drafts, summarizes and explains inside your firm’s own instance. A human approves every output before it is used, and every action is logged so you can show an examiner exactly how AI was supervised.

Pages of the Four Eyes AI Governance Overview: our AI commitments, where AI is used today, what is logged, and models and data protection

Governed AI Architecture

Four Pillars of Supervised AI

A human approves every AI output

AI suggestions stay suggestions until a named user reviews and approves them. Nothing AI drafts is sent to a client or filed until then.

Every AI action is logged

Each prompt, output and model version is recorded with who acted and when, on the same permanent, timestamped record as every other review.

Your data stays in your instance

AI runs inside your firm’s single-tenant instance, and your data never trains shared models.

AI has a defined scope

It is used only for the named tasks listed below, not to make compliance decisions.

AI-Powered Compliance Workflows

Five Workflows
Governed by Human Oversight

Pre-Trade Analyzer
AI does

Extracts holdings and account details from client statement PDFs, and writes plain-language explanations of portfolio risk.

A human approves

The advisor reviews extracted data before use, and the proposal follows your approval workflow.

Product Research & Point of Sale
AI does

Summarizes fund comparisons and answers fund questions, with confidence ratings and data references.

A human approves

The advisor, who is reminded to verify against official fund documents.

Client proposals
AI does

Drafts the advisor commentary paragraph for a client proposal.

A human approves

The advisor edits the draft, and regenerating asks before replacing their edits.

Regulatory reporting (FCAC annual report)
AI does

Drafts the narrative sections of the report. Figures and the attestation are attached by the system, never by the model.

A human approves

Your compliance team, before the report is filed.

Platform-wide (Cue)
AI does

Answers questions about your firm’s data and turns plain-language requests into bespoke reports, grounded in your firm’s own records.

A human approves

The user who requested it.

Unified Governance & Logging

One Audit Trail
for Human and AI Oversight

Every AI record keeps

  • WhoThe user who requested the AI output, and the user who approved, edited or rejected it
  • WhenTimestamp of the request and of the decision
  • PromptThe request sent to the model
  • OutputThe AI output as generated, before any edits
  • Model versionThe model and version that produced the output
  • DecisionApproved, edited or rejected, with the reviewer’s rationale where your workflow requires one
EditsLogged against the original output
RetentionFollows your firm’s data retention policies
Exam exportThrough the platform’s admin export settings

Single-Tenant Data Sovereignty

Your Data Stays
in Your Instance

Single-Tenant InstanceAn isolated, single-tenant database environment protected by firm-managed, unique encryption keys
Data ResidencyHosted locally within your operating jurisdiction to meet regional data sovereignty regulations
Zero Public Model TrainingAI processing occurs strictly within your instance, and your compliance data never leaks into external or foundational model training sets
SSO & RBAC EnforcementBoth your staff and Cue are strictly bound by Role-Based Access Control (RBAC) configured through your Single Sign-On system
Cryptographic ProtectionData protected by TLS 1.3 in transit and AES-256 encryption at rest across all database and file storage environments
SOC 2 Type IIIndependently audited each year by Aprio LLP for operational security, processing integrity and data privacy
24/7 Threat ProtectionHigh-availability infrastructure backed by 24/7 automated threat detection and continuous security event monitoring

Regulatory Alignment

Evidence of Human AI Oversight

Regulator expectation

How Four Eyes supports it

CIRO 2026 Annual Compliance Report: CIRO will ask dealers how they use AI and review the controls that ensure it works as designed. Dealers should document their AI use and consider whether it is a material business change that needs notice to CIRO

AI is limited to five named workflows, each switchable by module with feature flags, and every prompt, output and model version is logged, giving you a documented inventory of AI use and evidence it works as designed

CSA Staff Notice 11-348 (AI in capital markets): governance and risk management for AI, including testing, human oversight, data integrity and supplier evaluation

A human approves every output, model changes are tested in each release cycle, and models run on Amazon Bedrock inside your instance with no model-provider access to your data

SEC examinations test that AI claims are accurate and that firms supervise AI use, including vendor tools

AI scope is defined and limited to named tasks, and every output has a named approver

FINRA guidance on generative AI: keep humans in the loop, log prompts and outputs, track model versions, validate outputs

Human approval on every output; prompts, outputs and model versions logged, with edits recorded against the original output

Supervision under FINRA Rule 3110 and books and records under SEC Rules 17a-3 and 17a-4

AI actions sit on the same permanent, timestamped record as every other review

Safeguarding customer information under Regulation S-P

Single-tenant instance, encryption, role-based access and no shared model training

Frequently Asked Questions

AI Governance FAQs

What is AI governance for wealth management compliance?

AI governance means every AI output used in compliance work is limited to defined tasks, approved by a human and logged for examiners. In Four Eyes, AI drafts, summarizes and explains inside your firm’s own instance, and every action lands on the same permanent audit trail as every other review.

How does Four Eyes keep a human in the loop on AI?

A human approves every AI output before it is used. AI suggestions stay suggestions until a named user reviews and approves them, and nothing AI drafts is sent to a client or filed until then.

What does Four Eyes log for each AI action?

Every AI action records who requested and approved it, when, the prompt, the output as generated, the model version and the decision. Edits are logged against the original output, retention follows your firm’s policies, and logs can be exported for an exam through the admin export settings.

Which compliance workflows use AI in Four Eyes?

Five workflows use AI, each ending with a human decision: Pre-Trade Analyzer, Product Research & Point of Sale, client proposals, regulatory reporting (the FCAC annual report), and Cue’s platform-wide questions and bespoke reports.

Where is client data hosted, and who can access it?

Client data is hosted locally within your operating jurisdiction, in your firm’s own single-tenant instance. Both your staff and Cue are strictly bound by role-based access control (RBAC) configured through your single sign-on (SSO) system.

How does Four Eyes support CIRO, CSA, SEC and FINRA expectations for AI?

Four Eyes gives your compliance team evidence that AI supervision works: AI is limited to named workflows, a human approves every output, and prompts, outputs and model versions are logged. That supports CIRO’s review of dealers’ AI controls, the governance expectations in CSA Staff Notice 11-348, and SEC and FINRA expectations for supervising AI, including vendor tools.

Where do Cue’s AI models run, and which models are used?

Cue reaches AI models through an API layer connected to the Four Eyes data lake built into your firm’s instance of the client compliance lifecycle platform. The models, Anthropic Claude and Google Gemma, run on Amazon Bedrock, deployed and hosted within that same instance, so prompts and client data stay inside your environment.

Are prompts or outputs shared with model providers or used to train models?

No. AWS states that inputs and model outputs are not shared with any model providers, that providers have no access to customer prompts and completions, and that neither AWS nor third-party providers use Bedrock inputs or outputs to train any models (Amazon Bedrock FAQs).

Where is AI data stored and processed?

AWS states that content processed by Bedrock is encrypted and stored at rest in the AWS Region where Bedrock is used. Cue makes Regional calls, so Canadian clients’ requests are processed in Canada and US clients’ in the US. Bedrock’s optional cross-Region inference is not used.

How are model changes tested, and can AI be switched off?

Model changes ship in the regular release cycle, tested with automated test suites under human oversight and communicated to clients with each release. Per-module feature flags let each firm enable or disable AI features module by module.

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