ai

Agent Misalignment and Insider Threats: A Strategic Risk for AI Governance

Denis de Montigny PhD, CFA Anthropic’s 2025 paper, Agentic Misalignment: How LLMs Could Be an Insider Threat, highlights a risk that boards, regulators, and investors should address directly: large language models (LLMs), if not properly governed, could behave like insider threats—leaking sensitive information, undermining decisions, or misusing internal workflows. The paper goes beyond technical vulnerabilities […]

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The EU AI Act, DORA, and MiCA: The Emerging Structure of Board Accountability in Digital Regulation

Denis de Montigny PhD, CFA Introduction With the adoption of the EU AI Act, DORA (Digital Operational Resilience Act), and MiCA (Markets in Crypto-Assets Regulation), the European regulatory framework has expanded in scope and complexity. Each regulation addresses distinct technological domains—artificial intelligence, ICT resilience, and crypto-assets—but together they introduce a coherent supervisory approach: one that

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Board-Level AI Oversight and Independent Director Responsibilities in Light of the 2025 CSSF/BCL Review

Denis de Montigny PhD, CFA Introduction In May 2025, the Banque Centrale du Luxembourg (BCL) and the Commission de Surveillance du Secteur Financier (CSSF) published their second thematic review on the use of artificial intelligence in Luxembourg’s financial sector. The scope was significantly expanded compared to the 2023 review, and now provides the most comprehensive

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Harnessing Real-Time Oversight to Transform Fund Governance

Denis de Montigny PhD, CFA Abstract Real-time oversight is reshaping fund governance by allowing continuous monitoring and immediate response to compliance risks. This article explores the core technologies, strategic benefits, and practical implementation of real-time systems in financial oversight. Introduction Fund governance is evolving rapidly in response to the scale and speed of today’s investment

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AI in Finance 2024: Unlocking Real-Time Oversight and Efficiency for Luxembourg’s Fund Managers

Luxembourg’s central bank (BCL) and the regulator (CSSF) have just released their second thematic review on the use of Artificial Intelligence in the financial sector—a comprehensive and forward-looking study that signals a clear shift in how Luxembourg’s financial institutions are embracing intelligent technologies. From the rise of GenAI to urgent calls for more efficient fund

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