Servizio
Fractional CAIO for FinTech & RegTech
Senior AI leadership for regulated financial services. AI governance, model risk management, ACPR / BaFin / FINMA / FCA compliance, RAG over financial filings, AI fraud detection. For FinTech, neobanks, AI lending, and RegTech where AI accuracy is a compliance event, not just a UX issue.
A chi è rivolto
- FinTech and neobank CTOs scaling AI features under FCA / ACPR / BaFin / FINMA scrutiny
- AI lending and underwriting startups whose model risk policies need senior AI sign-off
- RegTech companies building AI-powered KYC, AML, transaction monitoring, or SAR generation
- Wealthtech and roboadvisors deploying AI for portfolio recommendations under MiFID II
- Crypto and DeFi platforms launching AI features under MiCA and EU AI Act scrutiny
- PE / VC-backed FinTech rollups deploying AI consistently across regulated portfolio companies
Cosa è incluso
- AI governance framework: model risk policies, eval methodology, refusal scoring, audit logging, all defensible to regulators
- EU AI Act compliance: risk-tier classification (high-risk for credit-scoring, fraud detection), Articles 9-15 documentation, GPAI obligations
- Sector-specific compliance: ACPR / BaFin / FINMA / FCA cross-walks, DORA (operational resilience), MiCA (crypto-asset providers)
- Production RAG over financial filings: SEC EDGAR, ESMA filings, prospectuses, regulatory updates, with citation accuracy non-negotiable
- AI fraud detection architecture: real-time transaction monitoring, anomaly detection, AML pattern recognition
- AI lending / underwriting: model architecture, bias testing (US ECOA + EU AI Act fairness requirements), explainability for adverse-action notices
- AI customer service for regulated products: refusal-tuned chatbots that won't give financial advice, escalation patterns, audit trails
- Model risk policies for board sign-off: risk taxonomy, eval gating, rollback procedures, vendor model risk assessment
Come lavoriamo
- 1
AI compliance audit (2 weeks)
Audit your current AI usage, model inventory, regulator exposure (which licenses you hold), compliance gaps under EU AI Act + sector regs. Deliverable: a written AI compliance posture with prioritised remediation plan.
- 2
Engagement start
Embedded with your tech leadership + compliance team within 1-2 weeks. Weekly syncs with CTO, monthly review with CRO/compliance lead, quarterly board-pack contributions on AI risk.
- 3
Ongoing cadence
4-6 days per month (FinTech engagements are typically higher-touch due to regulatory cadence). Available for regulator-response sprints when needed.
- 4
Quarterly AI risk reviews
Every 90 days: model risk register update, compliance posture report, vendor model assessment refresh, board-ready summary. Aligned with your existing risk-committee cadence.
- 5
Handover
When you hire a full-time Head of AI Risk or CAIO, clean handover with all model documentation, regulator correspondence logs, vendor contracts, and compliance artifacts intact.
Risultati che puoi aspettarti
- Defensible AI documentation for regulator scrutiny (FCA Dear CEO letters, ACPR thematic reviews, BaFin model audits)
- EU AI Act risk-tier classification with Articles 9-15 documentation for high-risk systems
- Model risk register with rollback procedures, eval gates, and quarterly review cadence
- RAG over financial filings with 100% citation accuracy and refusal scoring
- Fraud detection ROI improvements (typical: 15-30% reduction in false-positive AML alerts)
- AI lending models with bias-testing artifacts and adverse-action explainability
- Investor and acquirer due-diligence preparedness: AI risk posture documented
- Vendor model risk assessments for OpenAI / Anthropic / Mistral / on-prem alternatives
- DPIA and Transfer Impact Assessments for any non-EU AI vendor usage
- Board-ready AI risk dashboard updated quarterly
Domande frequenti
Do you understand financial-services regulators?
Yes. Working knowledge of ACPR (France), BaFin (Germany), FINMA (Switzerland), FCA (UK), DNB (Netherlands), CSSF (Luxembourg). Familiar with how each regulator interprets AI risk and the recent thematic-review patterns. Specific experience with EU AI Act intersection with financial-services regulation: many AI use cases trigger BOTH the AI Act and sector regs, and the interaction matters.
What's your AI in regulated finance background?
Shipped production RAG on financial filings for a Geneva-based hedge fund (2024-present): metadata-filtered retrieval, multimodal PDF parsing, per-query audit log, refusal scoring. Published research on Compliance-Aware RAG (CARAG) using SEC EDGAR. Familiar with sector-specific compliance frameworks (DORA, MiCA, MiFID II, PSD2 AI implications).
Can AI really pass FCA / ACPR scrutiny?
Yes, but only with the right architecture. Three non-negotiables: (1) RAG with citations, not generative-only, with every claim traceable to source; (2) refusal scoring, where the system MUST refuse when uncertain rather than fabricate; (3) per-query audit log, with every AI decision recoverable on demand. With these in place, AI is defensible to even sceptical regulators. Without them, you're building a compliance landmine.
What about model risk management?
A core part of every FinTech CAIO engagement: model inventory and risk classification, eval methodology (offline + production), rollback procedures, vendor model risk assessments. Aligned with SR 11-7 (US Fed) / SS1/23 (UK PRA) principles even for non-bank FinTechs, because acquirers and partners will ask.
Can you help with AI fraud detection specifically?
Yes. Architecture for real-time transaction monitoring, anomaly detection with explainable scoring, AML pattern recognition, SAR generation assistance. Critical design considerations: false-positive rate impact on customer experience, model drift in adversarial environments, explainability for compliance teams.
What about EU AI Act for AI credit-scoring or insurance?
AI credit-scoring and insurance pricing are EXPLICITLY high-risk under EU AI Act Annex III. This means Articles 9-15 obligations: risk management system, data governance, technical documentation, record-keeping, transparency, human oversight, accuracy/robustness/cybersecurity. CAIO engagement maps your specific system to these requirements with concrete documentation.
Crypto and DeFi: can you help under MiCA?
Yes. MiCA (effective 2024-2025) intersects with EU AI Act for any crypto-asset service provider deploying AI (trading bots, fraud detection, AML, customer service). Familiar with the dual-regulator interaction and how to structure AI deployment to satisfy both regimes simultaneously.
Do you only work with EU FinTechs?
No. UK, US, Singapore FinTechs also fit the practice. Cross-border FinTechs (US-incorporated, EU customers) are especially well-served because they need both regulatory worlds covered by one consultant. Time-zone overlap with US East Coast is 3-4 synchronous hours daily.
Parliamo del tuo progetto
Prenota una discovery call gratuita di 30 min. Nessun pagamento, nessun deck, nessuna sequenza di follow-up. Se l'AI non è la risposta giusta per il tuo problema, lo saprai durante la call.