All AI-generated content marked with prominent disclosure labels
Compliant
Human-in-the-Loop (HITL)
Manual review mechanism enabled for high-risk decisions
Compliant
Data Privacy Protection
Client data not used for AI model training
Compliant
Hallucination Detection
AI outputs verified through 4-layer validation pipeline
Compliant
Active Compliance Policies
KYC/AML Verification Policy
Active
All clients must complete Know Your Customer (KYC) and Anti-Money Laundering (AML) verification before account activation.
Automated checks performed using RegTech solutions. Manual review triggered for high-risk jurisdictions.
Last Updated: 2024-06-15
Version: 2.3
Coverage: 100% of Clients
Suitability Assessment Policy
Active
Client risk tolerance must be assessed and matched with product risk profiles.
Algorithmic suitability checks performed for all automated recommendations.
Periodic re-assessment required every 12 months.
Last Updated: 2024-06-10
Version: 1.8
Coverage: 100% of Recommendations
Transaction Limit Monitoring Policy
Active
Daily transaction limits enforced based on client type and risk profile.
Retail: $50K/day | HNW: $500K/day | Institutional: $5M/day.
Real-time monitoring with automated alerts at 80% threshold.
Last Updated: 2024-06-20
Version: 3.1
Alerts Triggered (24h): 12
AI Model Governance Policy
Under Review
Framework for responsible AI deployment including model validation, bias testing, explainability requirements,
and hallucination detection. Aligned with SFC Circular 24EC55 and HKMA guidelines.
Last Updated: 2024-06-22
Version: 1.0 (Draft)
Review Deadline: 2024-06-30
Regulatory Framework Alignment
SFC Circular 24EC55 (Nov 2024)
✓ High-risk AI use cases identified and monitored
✓ Prominent disclosure implemented for all AI interactions
✓ Human-in-the-loop mandatory for high-risk scenarios
✓ Governance framework documented and operational
HKMA Guidelines on Robo-Advisory Services
✓ Algorithm appropriateness and suitability assessment
✓ Regular model validation and performance monitoring
✓ Clear audit trail for all automated decisions
✓ Client suitability verification before execution
AMLO & PDPO Compliance
✓ Anti-Money Laundering ordinance compliance automated
✓ Personal Data Privacy Ordinance (PDPO) requirements met
✓ Data retention policies aligned with regulatory requirements
✓ Cross-border data transfer controls implemented