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Agent Research Company

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Regulatory analysis for agentic systems.

Most agentic systems entering production today were not designed with a specific regulator's framework in mind. This brief is the engagement that closes that gap, on paper, before it has to.

Audience
Incumbents · Regulators · Institutions · Builders
Engagement formats
F-01 · F-02
Typical duration
2–6 weeks
Outputs
Written analysis (40–80 pp) · Regulator obligations map · Gap register · Optional comment-letter draft
Jurisdictions
CSA · CIRO · AMF · FINTRAC · SEC · CFTC · FCA · MAS · BIS · IOSCO
Last reviewed
2026-04-12

The question

Most agentic trading deployments are designed against an internal architecture, not against a regulator's framework. The gap between the two is rarely caught at design time and is expensive to close after a system is in production.

CSA Staff Notice 11-348 and CIRO GN-3300 outline expectations for AI-mediated trading; SEC and CFTC have moved on autonomous-system supervision; FCA and MAS are tracking. The challenge is not finding the rules — it is mapping a specific multi-agent architecture to the obligations actually triggered by what the system does.

This brief is written. It produces an obligations map, a gap register, and a remediation plan that engineering and compliance can both read. It does not represent the firm to a regulator; it equips the firm to do that work itself, with outside counsel where required.

What this produces

  1. 01An obligation map across the relevant regulators, instrument-by-instrument.
  2. 02A taxonomy of which agentic behaviours map to which obligations.
  3. 03A gap register: what the system does that no rule clearly addresses.
  4. 04Recommended remediations, ranked by tractability and supervisory exposure.
  5. 05Optional: a comment-letter draft for an open consultation.

How it works

Three methodology steps from the standing approach, scoped to this brief.

  1. 01

    Frame

    Read the regulator filings, the codebase, or the internal memo. Write the question that is actually being asked.

  2. 02

    Build the artifact

    The artifact named in Outputs, above. Working notes during the build are visible.

  3. 03

    Hand it off

    A meeting, not a link. Six weeks of follow-up Q&A is included.

What it’s not

This brief is not a legal opinion. Where a regulator-licensed opinion is required — registration positioning, formal interpretive request, marketing review — I will say so and refer.

This brief is not a substitute for a CCO. It is a written input that compliance, legal, and engineering can read together; ongoing supervision remains the firm's responsibility.

This brief does not represent the firm to a regulator. Where representation is needed, outside counsel handles it; this analysis equips them.

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