Organise the risk team's rota around speed of consequence. A duty risk manager each day takes limit breaches and incidents, which may need classifying within hours. A weekly panel reviews requests to raise any agent's depth, which need evidence rather than speed. Risk acceptances go to named people by authority, and every reviewer stays independent of the line they review.
What lands in the risk team's queue?
The risk team is the second line. Its agents compile evidence and draft; they do not decide. What reaches the queue: notifications that an agent hit one of the organisation's own limits more often than expected, Attest runs that cleared no depth and dropped an agent to depth 1, incidents that may need classifying for internal or external reporting, requests from the first line to raise an agent's depth, and requests to accept a risk outside normal tolerance.
The chief risk officer owns the rota. The guide to AI agent skills by role sets out what risk managers need to know, and what a reviewer rota is explains the basic idea. A blank layout to start from is in the review queue rota template.
What are the steps?
- Agent, depth 1: reports items by type, business line and deadline. Breaches, certificate drops, incidents, depth requests, acceptance requests.
- Person (chief risk officer): sets response targets per type. Incidents classified within hours of notification; certificate drops reviewed the same day for operational impact; breaches reviewed within a working day; depth requests at the next weekly panel; acceptances within the time the business needs, but never without evidence.
- Person (chief risk officer): names a duty risk manager each day, with a deputy. They take incidents, drops and breaches.
- Person (chief risk officer): sets up a weekly depth-change panel. Two or three risk managers who review Attest evidence for each request.
- Person (chief risk officer): sets acceptance authority. Which risk managers may accept what, and what goes to the CRO or a committee.
- Agent, depth 2: drafts incident records and classifications. With links to the filed verdicts.
- Agent, depth 1: compiles Attest evidence for each depth request. Results per gate, drift, holds and refusals over the period.
- Person (assigned risk manager): decides each item. With reasons, recorded.
| Step | The agent does | Depth | Stays with a person |
|---|---|---|---|
| Incidents | Drafts record and proposed classification | 2 | Duty risk manager classifies |
| Certificate drops | Reports the drop and affected work | 1 | Assessing operational impact |
| Limit breaches | Reports breach and deciding bound | 1 | Root cause and remediation owner |
| Depth requests | Compiles Attest evidence | 1 | Panel decision |
| Risk acceptances | Drafts with evidence | 2 | Acceptance within authority |
| Reporting | Drafts the report | 2 | Sign-off and submission |
Why should depth requests go to a panel rather than the duty manager?
A depth request asks for an agent to be allowed to do more, usually because the first line wants fewer holds. Depth is earned, not configured: the role sets a ceiling, Attest evidence sets the depth, and the lower wins. Reviewing that evidence takes time and benefits from more than one view, because a capability can pass most gates and be weak on one that matters, such as escalation or scope.
A weekly panel gives each request a proper look, keeps decisions consistent across business lines, and stops the duty manager being pressed into a quick yes on a busy day. The panel records which gates it weighed and why it decided as it did.
Which controls matter, and what evidence do they leave?
- A duty risk manager is always named. Evidence: the rota for every working day.
- Reviewers are independent. Evidence: a recorded check that no reviewer is assigned to a business line where they work or approve.
- Incidents are classified within target. Evidence: notification and classification times. In the EU, DORA requires financial entities to classify and report major ICT incidents; other markets have their own rules.
- Depth decisions cite evidence. Evidence: the panel's note naming the Attest gates considered.
- Acceptances match authority. Evidence: the approver and the authority limit on each acceptance.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
What should be measured?
- Incidents classified within target.
- Certificate drops with an impact assessment the same day.
- Breaches with a named remediation owner, and breaches that recur.
- Depth requests decided at the next panel, and the share supported, challenged or rejected.
- Acceptances due for review and not yet reviewed.
Where does it usually go wrong?
The duty manager does everything. Without a panel, depth requests land on the duty manager and get decided quickly or not at all. Neither is right.
Independence slips. Risk managers seconded to a business line during a rollout keep reviewing that line afterwards. Check before every assignment.
Acceptances never expire. A risk accepted once is still accepted years later because nobody set a review date. Give every acceptance one.
Compliance and collections teams staff first-line queues with tighter clocks; compare the rotas for the compliance team and the collections team. For what a reviewer answers for in general, see what an AI agent reviewer is.
Questions people ask
Should the risk team approve held transactions?
No. That is the first line's job. The risk team reviews whether the system that approves them is safe, and samples the record to check.
How many people should sit on the depth-change panel?
Two or three is usually enough, with at least one who has not worked with the business line making the request. Rotate membership so knowledge spreads.
What should the duty risk manager do when an agent drops to depth 1?
Assess the operational impact with the first line the same day: what work is now held or manual, whether the first line can absorb it, and whether any customer commitments are at risk. Recertification is the first line's job; the risk view is whether the interim plan is safe.