Your advisers use AI to draft SOAs, analyse portfolios, and prepare client reviews. Do you know what data they're sharing?
Advisers paste portfolio details into ChatGPT for analysis, paraplanners draft SOAs with Claude, and practice managers summarise client reviews with Gemini. Vireo Sentinel shows you what's happening and catches sensitive financial records before they reach external platforms.
What's actually happening
SOA preparation
A paraplanner pastes a client's full financial position into ChatGPT to structure a Statement of Advice. Super balances, insurance cover, estate plans, and personal goals now sit on OpenAI's servers.
Portfolio analysis
An adviser copies a client's complete investment portfolio into Claude for rebalancing recommendations. Holdings, returns, risk profiles, and planned drawdown strategies on a third-party platform.
Pre-meeting client summary
A support officer drops three years of file notes into Gemini to prepare a review summary. Health disclosures, family disputes, beneficiary changes. The full picture of someone's life in a prompt.
Your clients share their whole financial lives with you. That trust has conditions.
85% of advisers now call generative AI a help to their practice. But 39% of firms cite security and privacy as a barrier to responsible AI adoption.
The data at risk in every client relationship
Advice firms hold some of the most sensitive personal information in any profession. Here's what flows into these services unchecked.
Portfolio and investment records
Asset allocations, fund holdings, transaction histories, capital gains positions, managed account details.
Personal financial positions
Income, expenses, debts, super balances, insurance coverage, tax positions, net worth calculations.
Identity and personal details
Full names, dates of birth, TFNs, addresses, marital status, dependant details, employer information.
Health and insurance information
Medical disclosures on insurance applications, health conditions affecting retirement planning, life insurance details.
Estate and succession planning
Wills, power of attorney details, beneficiary nominations, family trust structures, testamentary trust arrangements.
Advice documents
SOAs, ROAs, file notes, compliance reviews, risk profiling questionnaires, fee disclosure statements.
Your licence conditions already cover this
Advisers don't need new AI laws. AFSL conditions, professional standards, and privacy legislation already create obligations around how records are handled.
ASIC, AFSL conditions, and Privacy Act
AFSL general obligations (Corporations Act s912A)
In effect now
Licensees must have adequate risk management systems and ensure services are provided efficiently, honestly, and fairly. Using unvetted AI with client records is a risk management gap ASIC can act on.
Best interests duty (Corporations Act s961B)
In effect now
Advisers must act in the client's best interests. Exposing their records to third-party AI platforms without proper due diligence on handling practices is difficult to reconcile with this obligation.
Privacy Act 1988 (POLA Act 2024)
Statutory tort from 10 June 2025
Financial advisers hold health information, financial details, and family circumstances that all qualify as sensitive information. Individuals can sue for damages capped at $478,550. The OAIC can pursue civil penalties up to $50 million for serious breaches. Enforcement priorities for 2025-26 explicitly include AI-related privacy practices.
FASEA Code of Ethics (Standard 6)
In effect now
Requires financial advisers to take into account the broad effects of their actions on the client. Security of personal records is now inseparable from advice quality in a regulatory sense.
FCA and UK GDPR
FCA Principles for Businesses
In effect now
Principle 3 requires firms to organise and control their affairs responsibly. Principle 6 requires treating customers fairly. Both apply to how AI handles client records. The FCA expects firms to have appropriate governance over new technology.
Consumer Duty
In effect now
The FCA's Consumer Duty requires firms to deliver good outcomes for retail customers. Exposing personal records through uncontrolled AI usage works against every pillar of the Duty.
UK GDPR and Data Protection Act 2018
In effect now
DPIAs required before deploying new technology that processes personal information. Client financial records shared with AI platforms require a lawful basis. ICO fines up to 17.5 million GBP or 4% of global turnover.
Senior Managers and Certification Regime (SMCR)
In effect now
Senior managers are personally accountable for their areas of responsibility. If a team member leaks client records through an AI service, the relevant senior manager may face regulatory consequences.
MiFID II, EU AI Act, and GDPR
GDPR data minimisation
In effect now
Sending personal records to AI platforms beyond what's strictly necessary is a data minimisation violation. Financial details, health information, and family details all carry heightened protection. Fines up to 20 million EUR or 4% of global turnover.
MiFID II record keeping
In effect now
Requires firms to maintain records of all services and transactions. AI interactions involving client information should be captured in the firm's record-keeping framework, but rarely are.
AI Literacy requirements
February 2025
Organisations must ensure staff have sufficient AI literacy. Advisory firms need to show their people understand the risks of sharing client financial and personal details with these systems.
EU AI Act penalties
August 2026 for high-risk systems
Up to 15 million EUR or 3% of global turnover for non-compliance. AI systems used in creditworthiness assessment or insurance pricing are explicitly classified as high-risk.
SEC, FINRA, and state regulations
SEC Regulation S-P (amended May 2024)
Compliance from December 2025 (larger entities), June 2026 (smaller entities)
Requires written cybersecurity policies, notice to individuals within 30 days of breaches, and stringent third-party risk management. Updated rules expand obligations significantly.
FINRA 2025 oversight priorities
In effect now
FINRA's 2025 Annual Regulatory Oversight Report specifically highlights AI-related risks including leakage and requires member firms to supervise AI usage at enterprise and individual levels.
SEC Marketing Rule (206(4)-1)
In effect now
If advisers use AI to generate client-facing content, the output must comply with the Marketing Rule. But the input, client records used to generate that content, is the bigger governance risk.
State privacy laws
Varies by state
California CCPA/CPRA, Colorado AI Act (effective June 2026), and other state-level frameworks create additional obligations. Financial records often receive enhanced protections under state law.
How Vireo Sentinel helps financial advice firms
See what's happening
Which platforms your people use, how often, and what type of work goes in. Find the paraplanner who runs every SOA through ChatGPT before your compliance team does.
Catch client records before they leave
Real-time detection of names, TFNs, portfolio values, and personal details. Warns the adviser and gives them options: cancel, redact, edit, or override with a documented justification.
Prove governance works
Compliance reports with sections mapped to relevant frameworks. When ASIC asks about your technology risk management or a client asks how you protect their information, you have the evidence.
What this looks like in practice
The SOA draft
A paraplanner pastes a client's full fact find into ChatGPT to structure an SOA. The extension detects the TFN, super fund details, insurance information, and personal goals. The paraplanner chooses to redact identifiers and still gets a useful structure.
Retirement modelling
A couple's complete financial position goes into Claude to test drawdown scenarios. Vireo catches names, ages, account balances, pension details, and health disclosures across the prompt.
Insurance application review
Medical history and financial details typed into Gemini to draft insurance recommendations. Vireo flags health conditions, income figures, and personal identifiers. Every interaction is logged.
The annual review prep
Fifty client file notes dropped into ChatGPT at once to prepare review summaries. Vireo catches identifiers across every entry. Each flagged item is documented with the option to redact or override.
Built for financial advice firms
Warns, doesn't block
Advisers keep working on client files. Choices, not roadblocks.
Deploys in minutes
Browser extension. No agents, no proxies, no practice management integration.
Privacy by design
Personal information detected and handled in the browser, before it reaches our servers.
Affordable
Enterprise governance without the enterprise price tag. Built for practices that measure value in basis points, not IT headcount.
Explainable detection
No AI monitoring AI. Pattern matching your licensee or ASIC can understand. When they ask how it works, you can give them a straight answer.
See how your practice uses AI
Start freeVireo Sentinel supports your compliance efforts but does not provide legal advice. You remain responsible for your organisation's compliance obligations.