ClovieAgents that move money, under the controls your supervisors expect.
Ready-made packs for US and Canadian banks hold wires and account changes for a person, keep account numbers and SINs out of prompts, and keep every production agent in your model inventory.
US banks
| Policy | Decision | Mode |
|---|---|---|
| Approve money movement | Approval | Enforce |
| Approve account changes | Approval | Enforce |
| Keep account numbers out of prompts | Deny | Enforce |
| Keep SAR tools with BSA agents | Deny | Enforce |
| Production agents are in the inventory | Deny | Monitor |
| Reviews are not overdue | Deny | Monitor |
- Tool
- payments.initiate_wire
- Payee
- Added today
- Requested
- 2 min ago
Agents now reach payment rails and customer records.
Actions, not only answers
Agents start wires, add payees and reset credentials through the same tools your staff use.
Identifiers in prompts
Routing, account and social insurance numbers end up in prompts sent to third-party models.
Gaps in the inventory
Agents built in SaaS suites and cloud consoles never reach the model inventory or its reviews.
The guidance behind the bank packs
The rules and guidance that shape how AI is controlled in banking and capital markets, each linked to its official source.
- SR 26-2 / OCC Bulletin 2026-13Federal Reserve, OCC and FDICRevised model risk guidance that replaces SR 11-7. It leaves generative and agentic AI to each bank's own practices. (official source, opens in a new tab)
- OCC Bulletin 2023-17OCC, Federal Reserve and FDICInteragency guidance on third-party relationships: due diligence, contracts and ongoing monitoring. (official source, opens in a new tab)
- 12 CFR Part 30, Appendix BOCCInformation security standards for customer information, including access controls. (official source, opens in a new tab)
- FFIEC authentication statementFFIEC (OCC Bulletin 2021-36)Layered security and stronger checks for high-risk transactions and account changes. (official source, opens in a new tab)
- 31 CFR 1020.320FinCENSuspicious activity reports by banks, and the confidentiality of those reports. (official source, opens in a new tab)
- OSFI Guideline E-23Office of the Superintendent of Financial InstitutionsModel risk management, effective May 1, 2027. Its definition of a model includes AI and machine learning. (official source, opens in a new tab)
- OSFI Guideline B-10Office of the Superintendent of Financial InstitutionsThird-party risk management: risk assessment, due diligence and monitoring of providers. (official source, opens in a new tab)
- OSFI Guideline B-13Office of the Superintendent of Financial InstitutionsTechnology and cyber risk management, including change and release management. (official source, opens in a new tab)
- PIPEDAGovernment of CanadaPersonal information protection: identifying purposes, limiting use and safeguards. (official source, opens in a new tab)
- PCMLTFAGovernment of CanadaAnti-money laundering law, including the rule against disclosing suspicious transaction reports. (official source, opens in a new tab)
Clovie maps its controls to these texts to help your teams; it is not legal advice, and using Clovie does not on its own make an organization compliant with any of them.
Controls in the bank packs
12 controls, each a policy you install from the Policy Hub. Every one starts in monitor mode and changes nothing until you promote it after a simulation on your own traffic.
US banks
Seven policies for banks supervised by the Federal Reserve, the OCC and the FDIC.
- A person approves
Approve money movement
A person approves every wire, ACH, transfer, payment, payout or refund an agent starts.
US banks pack · mapped to FFIEC authentication statement - A person approves
Approve account changes
A person approves new payees, changed contact details, higher limits and credential resets.
US banks pack · mapped to FFIEC authentication statement - Blocked
Account numbers out of prompts
Blocks prompts with a routing number that passes its check digit, or a labelled account number.
US banks pack · mapped to 12 CFR Part 30, Appendix B - Blocked
SAR tools stay with BSA agents
Only agents your BSA team designates can see or use suspicious activity report tools.
US banks pack · mapped to 31 CFR 1020.320(e) - Blocked
Inventoried and reviewed
Stops a production agent with no risk tier, owner or model approver, or with a review overdue.
US banks pack · mapped to SR 26-2 inventory and validation - Blocked
Only reviewed third-party models
An agent with a list of allowed models can call only those models, whatever the request asks for.
US banks pack · mapped to Third-party risk guidance
Canadian banks
Five policies for federally regulated banks, used with the OSFI E-23 model risk pack.
- Blocked
SINs out of prompts
Blocks prompts with a social insurance number that passes its check digit, next to a customer word.
Canadian banks pack · mapped to PIPEDA Schedule 1, 4.7 - Blocked
Declare the purpose
Production requests carry a declared purpose, recorded with every request in the audit log.
Canadian banks pack · mapped to PIPEDA Schedule 1, 4.2 - Blocked
STR tools stay with AML agents
Only agents your AML team designates can see or use suspicious transaction report tools.
Canadian banks pack · mapped to PCMLTFA section 8 - A person approves
Approve technology changes
A person approves deployments, restarts and access, network or secret changes by production agents.
Canadian banks pack · mapped to OSFI B-13, change management - Blocked
Only assessed third-party tools
Production agents use MCP servers only once they are registered and given a data classification.
Canadian banks pack · mapped to OSFI B-10, principles 3 and 4 - Blocked
Model risk under E-23
Inventory, risk tier, owner, current review and sign-off before production, from the E-23 pack.
OSFI E-23 model risk pack · mapped to OSFI E-23, principles 2 and 3
How a payment an agent starts is governed.
Inside your own perimeter
Run Clovie as SaaS, or install it in your own cloud account or data center. Self-hosted installs keep prompts, traces and the audit log inside your network.
- SaaS
- Customer VPC
- On-premises
- Air-gapped
Your VPC or data center
The gateway, policy engine and console run in your account, next to the agents they govern.
Your models and keys
Provider keys stay with you, and self-hosted models sit in the same catalog as frontier ones.
Evidence on demand
Export decision logs and evidence packs for model validation, internal audit and examiners.
Controls mapped to the frameworks you answer to
- OSFI E-23: OSFI Guideline E-23, model risk management (Canada)
- NIST AI RMF: NIST AI Risk Management Framework
- ISO/IEC 42001: ISO/IEC 42001 AI management system
- OWASP Top 10: OWASP Top 10 for LLM applications and agentic AI
Questions
Does SR 26-2 cover AI agents?
The April 2026 guidance states that generative and agentic AI are outside its scope, and leaves controls for them to each bank's own risk management. The US banks pack applies its inventory, review and vendor practices to agents as a sound practice; it does not claim that SR 26-2 requires them.
Can we use the US and Canadian packs together?
Yes. A bank with operations in both countries can install both packs and scope each to the teams, projects or agents it applies to. Policies are evaluated together and the most restrictive decision wins.
Who approves a held payment, and where?
Approvers you name decide in Approvals in the console or in Slack. After approval the gateway lets the identical call through once; a changed call needs a new approval.
Will the packs block anything on day one?
Every policy installs in monitor mode, records what it would have done, and changes nothing until you promote it. Promote a policy to enforce after a simulation against at least seven days of your own traffic.
Do you replace our model risk management system?
No. Clovie keeps the agent inventory, risk tiers, owners and review dates current from live traffic and enforces them at the gateway. Your model risk team keeps its own validation process and records.
See the bank packs on your own agents.
We'll run the controls on your own agents in monitor mode and show what they would have held and blocked.