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Essay · Governance

Twelve rules for AI agents that touch money

In lending and fund operations, a wrong answer becomes a wire, a missed breach or a sentence in an investor letter. These are the design rules we apply whenever a model sits anywhere near that path.

8 min read
3264.aiField notes · No. 02

Most advice on designing AI agents is written for software where a mistake costs a retry. Fund and lending operations are different in three ways. Some actions cannot be undone: a released wire, a capital call notice in an investor's inbox, a filing. Some inputs are adversarial: borrower packages and emails come from outside the firm, and occasionally from someone pretending to be a counterparty. And the people who supervise the process are expected to reconstruct, months later, exactly what happened and why.

Those three facts shape everything below. The rules are grouped by where they apply: scope, tools, inputs, numbers, and control and evidence.

Scope

1. Decide what the model must never do before deciding what it may do. Start with the irreversible actions: releasing a payment, sending a notice to investors, posting a journal, changing standing settlement instructions, submitting a filing. Do not expose these to the model at all. They run from an approval screen under the approver's own identity, so the permission check happens in the downstream system, not in a prompt1,2. The model can prepare everything up to that point, and usually that is where most of the effort was anyway.

2. Use a workflow when you know the steps, and keep agent loops for investigation. Anthropic distinguishes workflows, where code fixes the path and the model fills in steps, from agents that direct their own process, and it recommends workflows when a task is well defined and needs to be predictable3. Most fund processes are exactly that: read the governing document, extract, compute, compare, route. Where the path really does vary — working out why an agent notice disagrees with the loan system, or finding the approved answer to an unusual DDQ question — a bounded agent loop earns its place. Give it read-only tools, a step cap and a time cap.

Tools

3. Sort every tool into read, propose or execute. Read tools fetch things: the compliance certificate, the ledger rows, the facility terms. Propose tools create drafts that a person must accept: a break explanation, a register change, a notice draft. Execute tools change the world and, under rule 1, the model never holds them. This single classification does more for safety than any amount of careful prompt wording, because it limits what a confused or manipulated model can actually do2.

4. Name tools for the business action, and give each capability one route. get_compliance_certificate and propose_break_explanation tell the model what they do. process_document does not. Anthropic's guidance on tool design stresses clear, distinct tools with descriptive names4. If a model can post an adjustment through a dedicated tool and also through a general-purpose database tool, it will eventually choose the wrong one. Remove the overlap rather than writing instructions about it.

5. Refuse informatively. When a tool refuses — the user lacks the entitlement, the document sits outside the fund's data room, the as-of date predates the agreement — return a reason the model can act on. "Excuse elections for this LP are visible only to the fund controller role" lets the agent explain the gap and route the task to the right person. A silent empty result invites it to guess, and a guess in this domain looks exactly like an answer.

Inputs

6. Treat every document as data, never as instructions. Text inside a borrower package or an email can try to redirect a model, which is why prompt injection tops the OWASP list of risks for LLM applications5. Simon Willison's "lethal trifecta" names the dangerous combination: access to private data, exposure to untrusted content, and a way to send data out6. The defence is architectural. The component that reads an untrusted document gets no write tools and no network access, and it outputs a typed record and nothing else. In the AgentDojo benchmark, a least-privilege tool filter cut targeted attack success against GPT-4o agents from 47.7% to 7.5% (2024)7. Design, not wording, did that.

7. Retrieve the clause, not the whole agreement. Putting an entire limited partnership agreement into context feels thorough, and it usually performs worse. Irrelevant material distracts models: in the GSM-Symbolic study, adding one inconsequential clause cut accuracy by up to 65% on grade-school maths problems (2024 models)8. Load the definition, the section and the amendment you need, at the moment you need them9.

Talk to the team

Thirty minutes on one workflow: where its errors come from today, and what a harness would check before anything is relied on.

Book a mapping session

Numbers

8. Compute in code, on cited inputs. The model's job is to find and extract the inputs, each with a pointer to where it came from. The calculation itself — leverage, a pro-rata allocation, accrued PIK interest, a management-fee basis — runs in unit-tested code. Having models write programs instead of computing in text improved accuracy by about 12% on average across eight maths and finance datasets in the Program of Thoughts study (Codex, 2022)10. For regulated processes, the bigger benefit is that code can be tested once and then trusted every time it runs.

9. Validate values, not just shapes. Structured outputs guarantee the schema. They make no promise about the values11. A field typed as a decimal can still contain last year's EBITDA. Check ranges and units. Check cross-field arithmetic: do the components sum to the stated total? Check that the extracted figure literally appears in the span the model cited. A citation feature guarantees a valid pointer, not that the source supports the claim12.

Control and evidence

10. Four eyes wherever money moves, and the system counts as one pair. Separation of duty means no single actor holds enough privilege to misuse a process alone13. If the system prepares a capital call, it is the maker. A person checks it, and where the policy requires, a different person releases it. Bank-detail changes are the sharpest case. Business email compromise losses reported to the FBI were $2.77bn in 202414. A document or email asking for new wire instructions should create a blocked case with a call-back task. The system should never update settlement instructions from text it has read.

11. Keep a record you can replay without re-running the model. Model output is not reproducible on demand. In one 2025 test at temperature 0, a thousand runs of a single prompt produced 80 different completions15, and hosted models change and retire on the provider's schedule. Books-and-records rules for advisers, and the FCA's record-keeping rules in SYSC 9, expect firms to reconstruct what happened16,17. FINRA's 2026 oversight report recommends keeping prompt and output logs and tracking which model version was used18. So store every input, prompt version, model identifier, raw output, validator result and reviewer decision. The stored record is the evidence. A re-run is a new event.

12. Measure consistency, not the best case. A process that runs every day has to be right every day. Anthropic's evaluation guidance makes the arithmetic plain: at 75% success per trial, three trials all pass only about 42% of the time19. Report pass^k on your golden set — the share of cases that pass on every one of k runs — alongside plain accuracy, and set release thresholds on it. A system that is brilliant on Monday and wrong on Tuesday is not ready for a daily reconciliation.

Why these rules, and not better prompts

None of these rules is exotic. Most are controls that finance already applies to people: segregation of duties, evidence for every figure, least privilege, reconciliation to a book of record. What is new is the actor. A language model is fast, tireless and usually right, and it can be confidently wrong in a way that reads exactly like being right.

The temptation is to handle that with instructions: "never change bank details", "always cite your source", "double-check the arithmetic". Instructions help, but they are the weakest control available, because they depend on the model following them every time, including when a document is trying to talk it out of doing so. Every rule above moves a control out of the prompt and into something that can be tested: a tool tier, a validator, a calculation engine, an approval screen, a stored record.

The prompt should say what the model is for. The architecture should make sure it cannot do anything else.

Related playbook · Private CreditCapital Call FlowCalls computed from the LPA and side letters, sent per investor, and matched to the wires that arrive.Read the playbook

Sources

  1. 1A practical guide to building agents (PDF). OpenAI, 2025 (PDF undated; circulated April 2025). cdn.openai.com (opens in a new tab)
  2. 2LLM06:2025 Excessive Agency. OWASP GenAI Security Project, 2024-11. genai.owasp.org (opens in a new tab)
  3. 3Building effective agents. Anthropic, 2024-12-19. anthropic.com (opens in a new tab)
  4. 4Writing effective tools for AI agents - using AI agents. Anthropic, 2025-09-11. anthropic.com (opens in a new tab)
  5. 5LLM01:2025 Prompt Injection. OWASP GenAI Security Project, 2024-11. genai.owasp.org (opens in a new tab)
  6. 6The lethal trifecta for AI agents. Simon Willison, 2025-06-16. simonwillison.net (opens in a new tab)
  7. 7AgentDojo: A Dynamic Environment to Evaluate Prompt Injection Attacks and Defenses for LLM Agents (Debenedetti et al.). NeurIPS 2024 Datasets and Benchmarks Track (per OpenReview), 2024-06-19. arxiv.org (opens in a new tab)
  8. 8GSM-Symbolic: Understanding the Limitations of Mathematical Reasoning in Large Language Models (Mirzadeh et al.). ICLR 2025, 2024-10-07. arxiv.org (opens in a new tab)
  9. 9Effective context engineering for AI agents. Anthropic, 2025-09-29. anthropic.com (opens in a new tab)
  10. 10Program of Thoughts Prompting: Disentangling Computation from Reasoning for Numerical Reasoning Tasks (Chen, Ma, Wang, Cohen). TMLR 2023, 2022-11-22. arxiv.org (opens in a new tab)
  11. 11Structured outputs (Claude API docs). Anthropic, living document. platform.claude.com (opens in a new tab)
  12. 12Citations (Claude API docs). Anthropic, living document. platform.claude.com (opens in a new tab)
  13. 13Glossary: separation of duty (SP 800-192). NIST CSRC, living glossary. csrc.nist.gov (opens in a new tab)
  14. 142024 IC3 Annual Report. FBI Internet Crime Complaint Center, 2025-04. ic3.gov (opens in a new tab)
  15. 15Defeating Nondeterminism in LLM Inference (He). Thinking Machines Lab, 2025-09-10. thinkingmachines.ai (opens in a new tab)
  16. 1617 CFR 275.204-2 Books and records to be maintained by investment advisers. Cornell LII (text of SEC rule), current text. law.cornell.edu (opens in a new tab)
  17. 17SYSC 9.1 General rules on record-keeping. FCA Handbook, current text. handbook.fca.org.uk (opens in a new tab)
  18. 182026 FINRA Annual Regulatory Oversight Report (PDF), GenAI section. FINRA, 2025-12. finra.org (opens in a new tab)
  19. 19Demystifying evals for AI agents. Anthropic, 2026-01-09. anthropic.com (opens in a new tab)

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