Using AI agents to support risk review and controls

A business owner reviewing risk and compliance data on a laptop at a tidy office desk
TL;DR

AI agents can automate routine risk and controls work such as vendor due diligence, control testing, and transaction monitoring, reducing manual effort and producing continuous evidence rather than annual snapshots. The regulatory obligations are equally real: UK GDPR Article 22, FCA Consumer Duty, and the EU AI Act all set requirements that apply regardless of whether a tool vendor handles the AI layer on your behalf.

Key takeaways

- AI agents for risk and controls automate tasks such as vendor questionnaire review, access rights checking, and transaction monitoring, providing continuous evidence rather than annual snapshots. - UK GDPR Article 22 restricts decisions based solely on automated processing with significant effects on individuals; the accountability obligation sits with your organisation, not the AI tool vendor. - The NCSC advises treating AI agents with system access as a security attack surface and recommends limiting what they can see and trigger, with proper access controls and audit logging in place. - Deloitte's 2023 research found 62% of organisations expect AI to play a significant role in risk management within three years, but only 40% believe they have adequate governance in place. - Before deploying an AI agent in a risk context, define its safe operating boundaries: what systems it can access, what actions it can initiate, and what always requires a human review step.

The annual supplier review lands in the calendar every October. Someone prints the spreadsheet, emails three departments for updated questionnaires, waits a fortnight for responses, and compiles a risk summary that is already out of date by the time the board sees it.

AI agents can run those same checks continuously, log the results automatically, and surface gaps before anyone has had a chance to compile the next review. The use cases are now practical enough for owner-managed businesses to take seriously.

What is an AI agent in a risk and controls context?

An AI agent is software that can take in data, make decisions based on defined rules or learned patterns, and carry out tasks without constant human direction. In a risk and controls setting, that means reading documents, testing whether a control has been met, logging the outcome, and escalating to a human when something falls outside tolerance.

Vendors including DataGrid, SmartSuite, and Advanced in the UK describe their products as “independent digital assistants” for tasks like risk assessment, vendor due diligence, and policy monitoring. The key distinction from a standard chatbot is autonomy. A chatbot waits for a prompt and gives an answer. An agent takes a goal, such as checking whether all users with admin rights have completed security training, and works through the steps to reach a conclusion, updating records and flagging exceptions along the way.

For owner-managed businesses, this rarely means building something from scratch. The practical version is embedding AI into existing systems, such as your CRM, ticketing tool, or finance platform, to review transactions, flag anomalies, or check policy compliance automatically. Many tools aimed at owner-managed businesses now include this capability under names like “automated workflows” or “smart alerts”.

Why does this matter for your business?

Risk and controls work is often the first thing deferred when the team is under pressure. Manual checking takes time, and annual reviews produce snapshots rather than visibility. AI agents reduce that friction. A continuous monitor can run in the background, logging evidence and raising alerts as they emerge, rather than waiting for the quarterly spreadsheet.

Deloitte’s 2023 research on AI in risk management found that 62% of organisations expected AI to play a significant role within three years, but only 40% believed their organisation had adequate governance in place. McKinsey reported that businesses using AI for risk modelling and fraud detection saw material cost savings or revenue improvements in 63% of cases.

For owner-managed businesses, the practical case is about capacity. A small team can keep vendor contracts, access rights, and policy compliance under ongoing review without hiring dedicated risk analysts, provided the AI is given clear criteria and a human is responsible for reviewing what it surfaces.

Accenture’s 2023 analysis suggested that automating compliance and control testing with AI can reduce manual effort by 30 to 50% in some financial services functions, though results vary considerably by how mature the underlying processes already are. That caveat matters: a business starting from a low baseline of documentation and process consistency will see smaller initial gains than one with clean data and well-defined controls.

Where will you actually encounter it?

AI agents for risk and controls appear most commonly in three areas: vendor and third-party management, control testing for compliance frameworks such as ISO 27001, and transaction monitoring for fraud or policy exceptions. You may already encounter this capability inside tools you use, presented as automated workflows or smart alerts rather than a named product category.

In vendor management, tools like SmartSuite embed AI agents directly into supplier records. The agent reads the vendor’s security questionnaire, cross-checks answers against requested evidence, and generates a risk score. A human still decides what to do with that score, but the time spent assembling the picture is substantially reduced.

For compliance frameworks, UK software vendors such as Advanced describe AI agents that test controls automatically, including access recertification, training completion checks, and evidence completeness. The aim is audit-ready evidence created as controls run, rather than compiled in a rush before the external review.

In financial services particularly, agents watch payment flows, detect anomalies based on learned patterns, and trigger actions such as freezing an account or routing a transaction for manual review. Lyzr describes this as continuous monitoring rather than periodic sampling, which changes what your controls can realistically catch.

When does it make sense, and when should you be sceptical?

AI agents work well in risk and controls when the task involves reading structured data against defined rules, and when speed of checking matters more than precision on edge cases. They struggle when data is inconsistent or fragmented, when the criteria for a risk require genuine human judgement, or when the decisions influenced carry significant consequences for real people.

The cautionary examples from algorithmic decision-making are instructive here. The Dutch childcare benefits scandal involved a risk-scoring system that wrongly flagged thousands of families as fraudulent, causing financial hardship and eventually prompting a parliamentary inquiry. The UK’s A-level grading algorithm in 2020 systematically disadvantaged students from certain schools and was ultimately abandoned by the government. In both cases, automated systems were used to make high-stakes decisions without adequate human oversight, and that was the failure, regardless of the technology involved.

The UK National Cyber Security Centre raises a separate concern. Integrating AI agents with broad access to internal systems introduces new attack surfaces, including prompt injection attacks where a malicious input manipulates an agent that has access to internal tools. The NCSC recommends limiting what AI systems can see and do, applying standard identity and access management controls, and testing explicitly for AI-specific threats. An agent with admin rights that can trigger payments or update records requires the same security discipline as any other privileged system account.

The practical test for an owner-managed business: if an agent’s flag leads to an action with significant consequences for a customer, a supplier, or a member of staff, a human review step needs to sit between the flag and the action.

A few terms come up repeatedly in conversations about AI agents for risk. UK GDPR Article 22 restricts decisions based solely on automated processing that have legal or similarly significant effects on individuals. Knowing when your agent crosses that threshold, and what safeguards are required, is not optional for any UK business with customers or staff.

The ICO’s guidance on explaining AI decisions sets out what organisations must communicate when AI influences decisions about people. If your agent is running credit assessments, access decisions, or anything that significantly affects customers, staff, or suppliers, a Data Protection Impact Assessment is likely required before deployment. The ICO’s AI and data protection risk toolkit makes clear that this accountability sits with the controller; using a vendor’s AI agent does not transfer the obligation.

For regulated businesses, the FCA’s Consumer Duty requires firms to avoid foreseeable harm and act in good faith. An AI-driven control that mis-classifies a customer or applies an unfair treatment creates a regulatory problem, not just an operational inconvenience.

Agentic AI security is the third concept worth adding to your vocabulary. McKinsey’s playbook for safe deployment of agentic AI recommends defining “safe operating boundaries” for any agent: what systems it can access, what actions it can trigger, and what happens when behaviour falls outside the expected range. A kill switch and a complete audit log are baseline requirements, not optional extras.

Finally, if your business serves EU customers, the EU AI Act applies regardless of where you are based. Systems used for creditworthiness assessment, employment decisions, or access to essential services are classified as high-risk. Fines for serious breaches can reach €35 million or 7% of global annual turnover.

The technology is ready. The governance thinking needs to keep pace. If you want to work through where AI agents fit into your risk and controls picture, Book a conversation.

Sources

- ICO (2023). Rights related to automated decision-making including profiling. Sets out when Article 22 of UK GDPR applies to AI-driven decisions and what safeguards organisations must provide, including the right to human intervention. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/guide-to-uk-gdpr/individual-rights/rights-related-to-automated-decision-making-including-profiling/ - ICO (2023). Explaining decisions made with AI. Guidance on transparency obligations when AI influences decisions about individuals, including what organisations must communicate and when a DPIA is required. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/explaining-decisions-made-with-artificial-intelligence/ - FCA (2022). Consumer Duty: Feedback to CP21/36 and final rules (PS22/9). Establishes the FCA standard requiring firms to avoid foreseeable harm and act in good faith, directly applicable when AI-driven controls affect customer outcomes. https://www.fca.org.uk/publication/policy/ps22-9.pdf - NCSC (2023). Guidelines for secure AI system development. Advises organisations to limit what AI agents can access and trigger, test explicitly for prompt injection and related threats, and apply identity and access management to AI components. https://www.ncsc.gov.uk/whitepaper/guidelines-secure-ai-system-development - EU (2024). Artificial Intelligence Act. Classifies AI systems used for creditworthiness assessment, employment, and essential services as high-risk; sets logging, human oversight, and transparency requirements with fines up to €35 million or 7% of global annual turnover. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1689 - McKinsey (2023). The State of AI in 2023: Generative AI's breakout year. Reports that organisations using AI for risk modelling and fraud detection saw material cost savings or revenue improvements in 63% of cases surveyed. https://www.mckinsey.com/capabilities/quantumblack/our-insights/the-state-of-ai-in-2023-generative-ais-breakout-year - McKinsey (2024). Deploying agentic AI with safety and security: A playbook for technology leaders. Recommends defining safe operating boundaries, applying least-privilege access, monitoring agent actions, and maintaining kill switches for AI agents with system access. https://www.mckinsey.com/capabilities/risk-and-resilience/our-insights/deploying-agentic-ai-with-safety-and-security-a-playbook-for-technology-leaders - Deloitte (2023). AI and Risk Management: Innovating with confidence. Finds 62% of organisations expect AI to play a significant role in risk management within three years, but only 40% believe they have adequate governance. https://www2.deloitte.com/global/en/pages/risk/articles/ai-in-risk-management.html - Accenture (2023). Reinventing compliance: Using AI to manage risk and reduce costs. Analysis suggesting that automating compliance and control testing with AI can reduce manual effort by 30 to 50% in some financial services functions. https://www.accenture.com/us-en/insights/risk/reinventing-compliance - Advanced (OneAdvanced) (2024). AI agents for compliance: Improve accuracy, reduce manual effort. UK vendor demonstrating AI agents for continuous access recertification, training compliance checking, and audit-ready evidence generation. https://www.oneadvanced.com/resources/ai-agents-for-compliance-improve-accuracy-reduce-manual-effort/

Frequently asked questions

Do I need to tell customers or employees if an AI agent is making decisions about them?

Under UK GDPR Article 22, if your AI agent makes decisions with legal or similarly significant effects on individuals based solely on automated processing, you must provide meaningful information about the logic involved and give people the right to request human review. The ICO is clear that the accountability obligation sits with the controller, not the AI tool vendor. If you are unsure whether your use case crosses the threshold, get advice before you deploy.

What does a sensible first AI agent project look like for a small team?

Start with a single, contained process: vendor questionnaire processing, access rights checking, or transaction anomaly alerts. Pick one where the output is a flag or a summary, not a final decision. Implement it inside a tool your team already uses, set clear criteria for what gets escalated, and have a person review anything the agent flags as significant before any action is taken.

How does the EU AI Act affect a UK-based business using AI for risk functions?

The EU AI Act applies to businesses that deploy AI systems affecting people in EU member states, regardless of where the business is based. Systems used for creditworthiness assessment, employment decisions, or access to essential services are classified as high-risk, with requirements around risk management, data quality, logging, and human oversight. Fines for serious breaches can reach €35 million or 7% of global annual turnover.

This post is general information and education only, not legal, regulatory, financial, or other professional advice. Regulations evolve, fee benchmarks shift, and every situation is different, so please take qualified professional advice before acting on anything you read here. See the Terms of Use for the full position.

Ready to talk it through?

Book a free 30 minute conversation. No pitch, no pressure, just a useful chat about where AI fits in your business.

Book a conversation

Related reading

If any of this sounds familiar, let's talk.

The next step is a conversation. No pitch, no pressure. Just an honest discussion about where you are and whether I can help.

Book a conversation