CRO SERIES | EPISODE 2 · ON DEMAND
The FCA’s Mills Review sets out how advanced AI will transform retail financial services by 2030 and beyond. Its 126 pages of recommendations apply existing duties, from Consumer Duty to the Senior Managers regime and operational resilience, to a market heading towards agentic AI.
The review is clear that senior managers stay accountable for the outcomes AI systems deliver to customers, whether a human or an agent dispensed the advice. Delegating an action to an agent leaves liability with the person who owns it.
The question for firms has moved from whether to adopt AI to how to govern it, prove it, and keep proving it.
For risk and compliance teams, that means evidencing the safety
of AI systems before deployment, during live customer conversations, and after the event.
Watch Aveni Chief Product Officer Ben Cave and Chief Commercial Officer Kent Mackenzie in episode two of the CRO Webinar Series, hosted by Kate Forster, who leads PR and communications at Aveni.
Ben and Kent work through the review’s recommendations: the independence of the second line, the role of evidence packs, the caution on frontier models, and the accuracy, latency and cost demands of continuous AI supervision.
The session closes with the concrete steps firms should take in the next six to twelve months.
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The senior manager carries the outcome whether a human or an agent delivered it.
Why verifying AI safety needs its own technology, separate from the system serving customers.
Simulate customer scenarios before launch, monitor live conversations at message level, evidence every one of them.
The evidencing problem with models whose training data and reasoning sit outside a firm's control.
Treat Mills as a control and infrastructure programme, and build for what the accountable senior manager needs to sign off.
Mills is a set of recommendations today. Continuous, proactive supervision looks certain to replace periodic review whatever final form those recommendations take, and the changes to monitoring, evidence and mindset take time to bed in. Firms that begin now will meet the final version already running the controls it describes.
