Begin by asking whether the decision belongs to compliance at all. Compliance officers handle held actions that need a second-line view, such as policy exceptions, marketing approvals and regulatory returns, and send operational decisions back to the business. For their own items, they check the rule applied, the evidence and its source, and decide with a reason.
Which held actions reach a compliance officer?
Agents in regulated firms route certain items to compliance by design. The usual ones are:
- Policy exceptions: an operations team wants to go outside a policy, and the agent drafts the exception request.
- Marketing and customer communications that need compliance sign-off before release.
- Regulatory reports and returns the agent has prepared from source data.
- Breach and incident log entries, including whether something is reportable.
- Responses to regulators' information requests.
- Complaints with a regulatory angle, such as a potential conduct failure.
Two other kinds sometimes arrive and should not stay: routine operational approvals that the business is trying to push onto compliance, and decisions that compliance will later need to test. Approving those compromises independence. Send them back with a reason.
What should the compliance officer check?
The rule the agent applied. Agents draft against the sources they are given. If the agent's policy library is current and sealed, its citation is a strong start. If it worked from an old version, or from a summary someone pasted into its brief, the draft may be confidently wrong.
The evidence and its provenance. A regulatory return built from ledger data is sealed; one that includes figures typed in by a business unit is declared and needs reconciliation. A complaint narrative from the customer is declared; the firm's record of what happened is sealed.
What the draft leaves out. Agents are good at drafting what was asked. A marketing approval request may not mention that the product changed last quarter. A breach entry may not consider whether the same cause affected other customers.
Who else must decide. Some decisions need a senior manager or a named function holder. In regimes with named individual accountability, the compliance officer's approval may be one of several.
How should the compliance officer decide?
| Held action | Approve when | Edit when | Decline when |
|---|---|---|---|
| Policy exception | The risk is understood, limited and time-bound | Scope or duration should be narrower | The exception would breach a regulatory requirement |
| Marketing approval | Claims are accurate, balanced and evidenced | Wording overstates or omits risk | Claims cannot be supported |
| Regulatory return | Figures reconcile to sealed sources | A figure needs correcting with evidence | Data is incomplete; hold for the business |
| Breach entry | Facts, cause and reportability are right | Impact is under- or over-stated | The assessment is wrong; redo it |
| Operational decision | Never compliance's call | Return to the business owner |
An example: a policy exception
Take a retail bank's compliance team. The agent holds an exception request from the lending operations team to waive a second identity check for existing customers applying online. The draft cites the policy and argues that existing customers have already been verified.
The compliance officer reads the record and sees the agent relied on the onboarding policy, a sealed source, but not the fraud team's recent note on account takeover in existing customer accounts, which sits outside its sources. They edit the exception: the waiver applies only where the customer logs in through strong authentication and their contact details have not changed in the past 90 days. The reason cites the fraud risk. The agent's owner is asked to add fraud bulletins as a source. Market detail for this kind of team is in AI agent training for compliance officers in retail banking in Australia.
Which controls protect compliance's role?
- Compliance approves only items within its mandate.
- Approvals are sampled by the head of compliance.
- Decisions cite the rule and the evidence.
- Compliance officers who approve held items hold a current reviewer credential, such as Certified Pryme Operator from Pryme Intelligence Academy.
The concept of a held action is defined separately. Other roles handle holds with different authority; see how loan officers handle an action an AI agent has held and how procurement officers do. The role map is in AI agent skills by role.
Questions people ask
Should compliance approve every action the agent holds?
No. Most holds are operational and belong to the business. Compliance should approve items within its mandate and set the rules for the rest.
Can an agent decide whether a breach is reportable?
It can draft an assessment. The decision to report to a regulator stays with people who are accountable for it.
What if the business keeps routing operational items to compliance?
Decline them with a reason, and raise it with the agent's owner. The routing is a limit that should be fixed.