Put the model where it can be explained
The recurring mistake in financial services AI is asking a language model to make
the decision. It produces an output that is often correct and never explainable,
and explainability is the binding requirement — for examination, for adverse-action
notices, and for your own internal risk function.
The architecture that works splits the two. The model does evidence work: extract
these fields, resolve this entity across sources, retrieve the governing policy,
summarise this case, draft this narrative. The decision is then made by a
documented rule set or a named human, working from that evidence.
The resulting explanation is concrete: here is the evidence, here is its source,
here is the rule version that applied, here is who approved it. Every part of that
is reconstructable months later.
Start with KYC review
If you are choosing a first use case in this sector, document-heavy review around an
existing human decision point is the strongest candidate. KYC onboarding and alert
triage both qualify: high volume, mostly extraction and assembly, deadline pressure,
and an analyst already in the loop whose judgement stays intact.
That last property is what makes it deployable quickly. You are not introducing a new
decision-maker into a regulated process — you are giving the existing one a prepared
file instead of a raw one.
Write the model risk documentation as you build
Documentation assembled before an examination describes what people remember the
system doing. Documentation written during the build describes what it does.
Intended use, limitations, data lineage, evaluation methodology and results by
category, known failure modes, monitoring, oversight design, and a change history for
every prompt, model and rule. Produced as a build artefact, in the format your model
risk framework already expects.