Skip to content
THE MILLS REVIEW | JULY 2026

The Mills Review validates the AI governance model Aveni was built for

The Mills Review sets out how firms will need to govern AI as it takes on more decisions and customer interactions. Aveni has spent seven years developing those capabilities specifically for regulated financial services.

AI can turn a single error into a population-scale problem

A human adviser makes one judgement at a time. An AI system can make thousands. If that decision pattern is flawed, the same error can reach every customer the system serves before anyone spots it.

Financial services governance was designed for people working at human speed. AI changes the scale and speed of decisions, creating a mismatch that existing oversight models were not built to handle. The Mills Review is the FCA’s response to that mismatch.

What the Mills Review asks firms to do

Accountability does not change. Firms remain responsible for every customer outcome, whether the work is done by a person or AI.
What changes is the evidence required: continuous monitoring, timely outcome data and oversight that operates at the same speed and scale as AI.

AI governance must operate at the same speed and scale as AI itself.
CRO SERIES | EPISODE 2 · ON DEMAND

Watch the Mills Review discussed:
what risk and compliance teams should do first

Watch on demand · 32 minutes
Ben Cave & Kent Mackenzie
Benjamin Cave

Benjamin Cave

Chief Product Officer, Aveni

Kent Mackenzie

Kent Mackenzie

Chief Commercial Officer, Aveni

The Mills Review describes the model. Aveni already delivers it.

The Mills Review points towards stronger oversight before, during and after AI systems are used. Aveni brings those stages together in one platform. Firms can capture interactions, test AI before deployment, monitor behaviour in live operation and review every outcome against a consistent standard.

01 | Capture

Assist

Every interaction starts here. Human advisor or AI agent, the conversation is captured the same way, the moment it happens.

02 | Compliance Suite
PRE

Approve

Agent behaviour validated before a real customer sees it.

DURING Live

Assure

Conduct and vulnerability signals caught live, on every channel.

AFTER

Detect

Every closed case assessed into audit-ready evidence.

03 | Intelligence Layer

Intelligence Engine

FINLLM · 150+ MODELS
L1

Fast · Live · Continuous

Real-time classifiers over every interaction.

Conduct Vulnerability
L2

Deep · Specialist SLMs

Domain-trained models for advice reasoning.

Advice Suitability
L3

Generalist LLMs

Frontier models for edge-case orchestration.

Reasoning Synthesis
Assist capturing client meetings

Assist:
Capture every interaction

Assist records, transcribes and structures customer interactions as they happen. This creates a reliable record that firms can use for documentation, oversight and later review.

Approve testing AI across customer personas

Approve:
Test AI before deployment

Approve turns your policies and risk appetite into test criteria. AI systems are assessed across realistic customer scenarios so teams can identify weaknesses before deployment. Deployment decisions are supported by evidence from testing.

Assure monitoring a live AI session

Assure:
Monitor AI continuously

Assure monitors AI systems while they are in use. It tracks behaviour against expected limits, identifies drift and gives teams the information they need to intervene quickly.

Detect assessing a completed case

Detect:
Review every outcome

Detect assesses completed interactions, whether handled by a person or an AI system, against one consistent standard. It gives firms broader coverage, clearer evidence and a more complete view of customer outcomes.

The Intelligence Engine’s three model layers

Intelligence Engine:
The intelligence behind every Aveni product

The Aveni Intelligence Engine combines fast classifiers, financial services models and general-purpose language models.

Mills Review resources

The Mills Review

Read the FCA’s full Review and its seven recommendations for the future oversight of AI in retail financial services.

Read the Review on the FCA’s website

The Mills Review, mapped

See how the six recommendations translate into practical AI governance.

Download the briefing

Map the Mills Review against your firm

In a 30-minute briefing, our team will map the Mills Review’s recommendations against your current governance approach and show where Aveni can support stronger oversight today.