Sub-function
Compliance & Ethics
Owns compliance case work end to end inside Legal. Runs 3 lines across 18 stations, drains the repeatable share into the LEGAL tower, and holds 4 human gates.
Estate rating
BBB
73 / 100
Screening and attestation run at scale without humans. Every sanctions hit and every ethics report is handled by a named person — an agent must never close a whistleblower case.
Agents
9
Lines
3
Units / wk
16,344
Timetable vs actual
17.8h → 20.1h
Cost / unit
$5.37
was $17
Run-rate saving
$9.8M
annualized at this volume
The 9 agents running this sub-function
Grouped by what they are for, not by where they sit. The agent org is process-shaped.
Compliance Orchestrator
Owns the compliance & ethics lane end to end. Sequences the other agents, holds the timetable, and decides what surfaces to a human.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Policy Attestation Agent
Runs the repeatable portion of compliance & ethics inside the shared transaction spine at spine cost and spine controls.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Conflict of Interest Agent
Executes the compliance & ethics step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Gifts & Hospitality Agent
Executes the compliance & ethics step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Whistleblower Triage Agent
Executes the compliance & ethics step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Training Compliance Agent
Executes the compliance & ethics step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A3 · escalates to Escalates to Chief Compliance Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Third-party Screening Agent
Holds the rules that bind every other agent in compliance & ethics. Versions them, tests them against live decisions, and blocks work that breaches them.
ceiling A3 · escalates to Escalates on any decision that would breach a live policy version, with the clause cited.
Compliance Policy Agent
Holds the rules that bind every other agent in compliance & ethics. Versions them, tests them against live decisions, and blocks work that breaches them.
ceiling A3 · escalates to Escalates on any decision that would breach a live policy version, with the clause cited.
Compliance & Ethics Challenger Agent
Adversarial reviewer for compliance & ethics. Argues the opposite case on every position and flags where the evidence does not carry the claim.
ceiling A3 · escalates to Escalates when a ratified position is still running against a break condition it flagged.
Estate rating breakdown
Seven control dimensions. Judgment readiness runs against autonomy on purpose.
People
What the humans stopped doing, and what they do now.
Redeployed into control design and independent testing.
Lines running in this sub-function
Each line is a workflow. Click a line to walk it station by station.
Strategy positions this sub-function holds
An agent that only executes is a robot. These are the calls it made, the argument against each one, and what would prove it wrong.
Compliance & Ethics Operating Position
Ratifiedv4Is the current cost per compliance case defensible against external comparators once inference spend is counted in full?
Hold the ceiling at A3 for compliance & ethics. Screening and attestation run at scale without humans. Every sanctions hit and every ethics report is handled by a named person — an agent must never close a whistleblower case. Raise it only after two consecutive quarters where the override rate stays under five percent and every override has a written cause.
confidence
76%
The challenge — Compliance & Ethics Challenger Agent
Compliance & Ethics Challenger Agent argues the recommendation leans on 4 quarters of data from a period with no volume shock. The confidence band overlaps the alternative, and the position does not say what it would take to be wrong. Recorded as a dissent, not a block.
Break conditions
- ·Override rate rises above 15 percent for two consecutive months
- ·Cost per compliance case stops falling while volume keeps rising
- ·A control failure in this lane reaches a customer or a regulator
Evidence gaps
- ·No external comparator on a like-for-like unit definition
- ·Exception cases under $19k are sampled, not fully measured
| Alternative considered | Cost | Risk | Verdict |
|---|---|---|---|
| Hold the current position | $860k run rate | Known and priced. Cedes ground if comparators move faster. | not selected |
| Raise the ceiling one level now | $1257k to build controls | Override rate is 5 percent; raising the ceiling before that settles imports the error into production. | rejected on evidence |
| Move the exception tail to the spine | $1058k transition | Loses local context. Rework risk on the cases that are hardest to recover. | selected |
Ratified 6 months ago. Measured since: cost per compliance case fell 34 percent against a forecast of 34 percent.
Policy register
The rules the agents above are bound by. Version, owner, approver, and the agents each rule constrains.
| Ref | Rule | Scope | Owner agent | Approved by | Version | Status |
|---|---|---|---|---|---|---|
| LG4-POL-200 | Compliance & Ethics Decision Envelope Agents in this lane may act without a human when the compliance case sits inside the stated value, risk and confidence envelope. Outside it, the unit holds at a gate with a named approver and a running clock. binds 5 agents · Global · EU | envelope | Third-party Screening Agent | Chief Compliance Officer | v3.3 | under review |
| LG4-POL-201 | Compliance & Ethics Evidence Standard Every autonomous decision writes inputs, the rule version applied, the model and prompt version, the output and a reversal path. An action with no evidence record is treated as a control failure, not a fast decision. binds 5 agents · Global | evidence | Third-party Screening Agent | Chief Compliance Officer | v4.8 | Active |
| LG4-POL-202 | Compliance & Ethics Escalation Rule Escalation is mandatory when confidence falls below the floor, when two options sit inside the confidence band, or when a break condition on a ratified position fires. Chief Compliance Officer owns the response clock. binds 5 agents · EU · UK · US | escalation | Third-party Screening Agent | Chief Compliance Officer | v2.9 | Active |
| LG4-POL-203 | Compliance & Ethics Autonomy Ceiling The ceiling for this lane is 76 on the platform scale. Screening and attestation run at scale without humans. Every sanctions hit and every ethics report is handled by a named person — an agent must never close a whistleblower case. The ceiling is a governance decision, not a technical limit, and only Chief Compliance Officer can propose moving it. binds 5 agents · US · Canada | ceiling | Third-party Screening Agent | Chief Compliance Officer | v5.3 | under review |