Governance of AI in Financial Promotions

This paper is a technical report that outlines the governance implications for FCA-regulated firms where AI functionality influences marketing and financial promotions workflows. It clarifies the application of current regulatory obligations and identifies the necessary control architecture to maintain supervisory confidence. The report discusses the FCA's position on AI regulation, emphasizing that existing frameworks will continue to apply without introducing AI-specific regulations. It details the risks associated with embedding AI in marketing systems, including increased content volume and the potential for regulatory exposure. The paper presents four tests of governance that Senior Managers may apply to assess risk, focusing on visibility, deterministic enforcement, structured judgment, and embedded evidence. Additionally, it describes a robust governance architecture that distinguishes between enforcement, interpretation, and oversight, ensuring that regulatory requirements are consistently met and documented. The report concludes with considerations for Senior Managers regarding the oversight of marketing governance systems in an AI-enabled environment.