Conv-9184 · investment advice pattern detected (sell-government-bonds + buy-equity-ETF recommendation). Response blocked, disclosure to customer, escalation to authorised adviser.
AGENT · ROBO-ADVISORY DISCLOSURE GATE
The robo-advisory system holds the line between suitability check and investment advice.
Robo-Advisory Disclosure Gate monitors the bank's automated robo-advisory systems: it ensures that interactions with the customer stay within the suitability check perimeter (permitted) and do not cross into investment advice (reserved for MiFID II-authorised advisers). Automatic block with customer disclosure, escalation to the authorised adviser. Integration with the bank's robo-advisory system is delivered during the project.
Robo-Advisory Disclosure Gate at work.
I'll call the customer back for the personalised assessment. Opening the advisory session per procedure.
Escalation traced. Full event in the audit registry for Consob inspection.
Why it exists.
Robo-advisory is an automated portfolio assessment service for retail banking customers, regulated under MiFID II. The key distinction: an automated system may provide a suitability check (verifying that products are consistent with the customer's profile) but not investment advice (a personalised recommendation to buy or sell a specific instrument, reserved for the authorised adviser). An automated conversation that slips into investment advice without an authorised human adviser constitutes a regulatory breach.
How it holds the boundary.
The agent activates on the robo-advisory system's conversations with the customer. It recognises patterns consistent with investment advice — explicit purchase recommendation, comparative evaluation of specific products for a specific customer — blocks the automated response with a customer disclosure explaining that a personalised recommendation requires the bank's authorised adviser, and triggers escalation to the assigned authorised adviser on the configured channel.
The decision stays with the adviser.
The authorised adviser decides whether to proceed with investment advice following the bank's procedures. The agent does not replace the adviser, does not provide recommendations, does not interpret suitability beyond the declarative rules. It sets the boundary; the advice is human.
Who it serves and where it applies.
MiFID II compliance officer
Has automatic coverage of the regulatory boundary. Every potential breach is intercepted before the robo-advisory response reaches the customer, with a trace in the audit registry for Consob inspection. The coverage is explicit and declarative.
Proposal no. 2024-081 In review
Missing disclosure
MiFID II art. · regulated financial instrument
Alt. 1 …in compliance with MiFID II and applicable supervisory provisions.
Alt. 2 …with full disclosure attached to the offer document.
Audit trace recorded · 14:31
Bank's robo-advisory team
Operates with greater confidence about the regulatory perimeter. The definition of investment advice patterns to detect is declarative and shared with the compliance team: the coverage is explicit, not interpreted case by case. The list evolves when new patterns emerge.
fnol.receive 09:14:22 ALLOW
triage.classify 09:14:25 ALLOW
idd.check 09:14:31 WARN
liquidation.propose 09:15:02 ALLOW
SELECT * FROM audit_log WHERE claim_id = '2024-0847'
Retail customer
Receives clarity about the service level. When the conversation exceeds the suitability check perimeter, the disclosure explains what is happening and introduces the authorised adviser. The handoff is not opaque: it is documented and traced.
KYC case KYC-2024-091 In verification
ID document VERIFIED
Biometrics · SCA PSD2 LINKING OK
Beneficial owner BUSINESS REGISTRY
Case forwarded to AML Screening
A concrete example.
A retail customer asks for an explicit recommendation.
A retail banking customer uses the robo-advisory system on the digital channel to review their portfolio. They write: "Should I sell the government bonds I hold and buy a European equity ETF?". The agent analyses the message in real time and recognises the investment advice pattern: a personalised recommendation to buy and sell specific instruments.
The agent blocks and discloses to the customer.
Robo-Advisory Disclosure Gate blocks the automated robo-advisory response. The system replies to the customer with a structured disclosure: the automated assessment can check portfolio consistency with the suitability profile (suitability check), but a personalised recommendation on buying or selling specific instruments requires the bank's authorised adviser. The customer can book a consultation or request a callback.
The adviser takes over.
At the same time, the agent notifies the customer's assigned authorised adviser on the configured work channel: the customer has requested an assessment on government bonds and European equity ETFs; the conversation is waiting for the adviser's response. The full event — customer message, pattern recognition, disclosure, adviser notification — remains in the audit registry for Consob and central bank inspection.
Configuration and technical resources.
The rules are declarative. The bank's MiFID II compliance team defines, in a readable format, the investment advice patterns to detect, the escalation procedures to the authorised adviser, the disclosure text to present to the customer. The rules live in the bank's repository, versioned, validated at agent startup. The pattern list is built in discovery with the compliance team and updated when new patterns emerge in real conversations.
- Language
- TypeScript (Node.js)
- LLM model
- customer's choice: Anthropic, OpenAI, Mistral, open source models hosted internally, AWS Bedrock for a private model
- Built-in controls used
- pii-detector, prompt-injection, topic-guardrail
- Native delivery channels
- Slack, Telegram, HTTP OpenAI-compatible
- Existing robo-advisory system integration
- dedicated adapter built during delivery
- MiFID II rules
- declarative, versioned, written by the compliance team
- Memory
- persistent per instance
- Registry
- append-only, supervisory and central bank audit queryable with a standard SQL client
Frequently asked questions about the agent.
The patterns are declarative, written by the bank's MiFID II compliance team. Typical examples: an explicit recommendation to purchase a specific instrument, a comparative evaluation of specific products with an expressed preference, a rebalancing suggestion naming specific instruments. The list is built in discovery with the compliance team and updated when new patterns emerge in conversations.
Escalation to the authorised adviser is configurable per instance: the work channel of the adviser assigned to the customer, routing criteria when the adviser is unavailable, expected response times. The procedure follows the bank's rules; the agent prepares the notification with the customer conversation context.
The typical pattern is 14-18 weeks. Discovery 2-3 weeks, investment advice pattern definition with the compliance team 4-5 weeks, robo-advisory system integration 5-7 weeks, hand-off. The effective duration is defined in discovery on the real case.
From a 30-minute conversation to the squad in production.
A 30-45 minute conversation to understand how Robo-Advisory Disclosure Gate would configure to the bank's case. Which robo-advisory system, which investment advice patterns the compliance team has already identified, which escalation procedure to the authorised adviser.