Give the compliance officer ten working days of the real decisions their role makes around agents: monitoring alerts the agent drafted, marketing reviews, breach log entries and requests to raise an agent's depth. The head of compliance or a certified senior decides each one independently. The officer passes with at least 95 decisions in every 100 right and no missed red line, such as an unlogged reportable breach.
What is the practicum, and who owns it?
A practicum is supervised practice on live work against a fixed bar. For a compliance officer working with agents, live work comes in two kinds. Some decisions concern the agent's output: alerts it raised, breach entries it drafted, marketing it pre-reviewed. Others concern the agents themselves: whether a capability should move up a depth on the evidence from recertification.
The head of compliance owns the practicum and either supervises or names a certified senior officer. The officer owns their decisions and written reasons. Where a practicum case reaches the regulator, the head of compliance acts as they would on any case, and the practicum never delays it.
How do you build the queue?
Compliance decisions take time. Eight to twelve a day gives around 100 over the fortnight, which is the floor for a 95-in-100 bar to mean anything. Include:
- monitoring alerts drafted by the agent, from transactions or communications, to confirm or close;
- breach log entries drafted by the agent, to confirm, amend or reject;
- marketing or customer communications pre-reviewed by the agent, held for approval;
- regulatory change mappings drafted by the agent, to accept or correct;
- depth change requests with recertification evidence, to approve, defer or condition;
- refused or withheld actions that a business team has asked compliance to "unblock".
Seed anonymised past items for thin types. For example, a seeded depth request might show a payments capability passing all seven gates for depth 4, but on a replay set of mostly small, routine payments. The correct decision is to defer or condition the increase until the replay includes harder cases, not to approve because every gate passed.
The steps
- Person (head of compliance): brief the officer on the bar, red lines and log.
- Agent, depth 1: route items to the practicum queue, tagged by type.
- Agent, depth 2: present each item with its draft, the sources and their provenance, and for depth requests, the gate results.
- Person (officer): decide and write the reason.
- Person (senior): decide independently, then compare.
- Person (senior): act on the agreed outcome: sign approvals, confirm breaches, condition depth changes.
- Agent, depth 1: log both decisions, the match and any red-line flag.
- Person (senior, then assessor): review the log at the end.
| Step | The agent does | Depth | Stays with a person |
|---|---|---|---|
| Monitoring | Reads activity and drafts alerts | 1 and 2 | Confirming or closing |
| Breach log | Drafts entries | 2 | Confirming and reporting |
| Marketing review | Pre-reviews and holds | held | Approval |
| Regulatory mapping | Drafts policy impacts | 2 | Accepting changes |
| Depth request | Presents gate results | 1 | Approve, defer or condition |
| Log | Records decisions | 1 | Confirming |
How do you set and apply the bar?
A decision is correct if it matches the senior's, or the senior agrees it was sound and well reasoned. For compliance, the reason carries as much weight as the outcome.
The red lines: failing to log or escalate a breach that should be reported; approving a communication that is misleading; approving a depth increase without evidence from hard cases; treating a withheld action as something compliance can unblock. Withheld actions are refused at the platform floor for every agent at every depth; customers narrow agents with their own limits. Confusing the two is a red-line misunderstanding for this role. One miss fails the practicum.
Conditions count as part of the decision. "Approved subject to monitoring" is too vague to score; "approved at depth 3 for payments up to the current limit, with a sample of releases reviewed weekly until the next recertification" can be tested.
Which controls matter, and what evidence do they leave?
- Senior action on every outcome. Evidence: the senior's sign-off in the append-only record.
- Independent decision. Evidence: the senior's decision logged before comparison.
- Written reasons. Evidence: the officer's reason per item.
- Daily debrief. Evidence: a line per mismatch.
- Full log. Evidence: the practicum log template for compliance officers.
What should you measure?
Correct decisions out of the total, by type. Red-line misses (zero). Depth requests the officer conditioned and whether the conditions were specific and testable. And how often the officer amended the agent's breach drafts, with whether the amendment was material.
Where does it usually go wrong?
The queue has no depth requests, because none happened to fall in the fortnight. That leaves the most consequential decision untested. Seed them.
The senior and officer sit on the same project and agree by habit. Use a senior from another area where possible.
The officer treats gate passes as approval. Gates show what was tested; the officer asks what was not.
The practicum crowds out real deadlines. Plan it away from regulatory reporting dates. Lending teams run a parallel practicum, and the practicum log template for loan officers shows how the same record adapts. Compare running a practicum for loan officers.
Where the Academy fits
Pryme Intelligence Academy's Certified Pryme Operator practicum uses the same bar: two weeks of real review decisions, at least 95 in every 100 correct and no missed red line, signed off by a Pryme assessor. Compliance officers who lead regulated, multi-agent deployments may go on to the Architect track, which ends with a board review by two Pryme assessors. More in the guide to AI literacy and certification for people who work with agents.
Questions people ask
Should the practicum include regulatory reporting?
Include the decision to report, not the filing mechanics. Any real report goes through the normal route at once.
Can an officer from a small firm be supervised externally?
Yes, if the supervisor holds a current certificate and is given the access their review needs under the firm's data rules.
How should the officer record a deferred depth request?
With the reason, the evidence still needed and a date to revisit. A deferral without conditions is a decision nobody can test.