Following Risk Evolve 2026, Caitlin Like from Behavox explains why firms struggle to demonstrate regulatory defensibility despite heavy investment in surveillance technology. The issue is not a lack of tools, but fragmented control environments. Disconnec
A Q&A
with Caitlin Like, Global Head of Customer Success and Account Management,
Behavox. Following her keynote presentation at CeFPro's Risk Evolve 2026 in
London, Caitlin Like sat down to discuss why controls fragmentation remains the
most persistent barrier to defensibility for financial institutions, and how
AI-native platforms are changing the equation.
The term "controls fragmentation" came up
throughout your session at Risk Evolve. What does that mean in practice for a
compliance or risk leader at a major bank?
In most large financial institutions, the controls that
govern conduct and market integrity have been built incrementally — by product,
by region, by risk type. Communications surveillance sits in one system. Trade
surveillance sits in another. Policies and procedures live in a document
repository or GRC platform that has no real-time connection to either. Case
management is a fourth system. When an examiner asks for evidence that a
control worked — or asks your team to reconstruct a conduct timeline — someone
has to manually stitch together records from all of these systems. That manual
reconstruction is expensive, slow, and error-prone. But the deeper problem is
this: the same conduct or market abuse risk has to be defined multiple times
across those systems, and the definitions often diverge. The result is a
controls programme that performs inconsistently and cannot produce reproducible
evidence at scale. That is what fragmentation looks like from the inside — and
it's why firms with significant technology investment still fail to demonstrate
defensibility when it matters.
You talked about "defensibility-grade"
integration as the standard to aim for. What distinguishes a
defensibility-grade programme from one that merely has multiple surveillance
tools in place?
The test is simple: can you trace a regulatory obligation
through your control design, through your monitoring, through your case
outcomes, and through your remediation — with reproducible evidence at every
step? Most firms can demonstrate that they have surveillance tools. Fewer can
demonstrate that those tools are enforcing specific policies, that those
policies map to specific regulatory obligations, and that when something goes
wrong, the system produces an auditable record of what was detected, what was
investigated, and what was done about it. Defensibility-grade integration means
the evidence chain is intact before the examiner asks for it — not
reconstructed after the fact by analysts pulling records from disparate
systems. The distinction between "we have surveillance" and "our
surveillance is defensible" is exactly where firms are being challenged
today.
AI was a dominant theme across the Risk Evolve agenda
this year. How does Behavox think about AI specifically in the context of
controls — and how do you address the model validation challenge?
The controls context is unforgiving for AI. Unlike a
recommendation engine or a pricing model, an AI system operating in
surveillance is subject to regulatory scrutiny, must produce explainable
outputs, and must pass model validation under frameworks like SR 11-7. The
failure mode of generic AI in this context is well-documented: models that
cannot be validated, that produce unexplainable alerts, and that generate high
false-positive volumes because they have not been tuned for specific control
problems. Behavox's approach is purpose-built AI for specific controls use
cases — our own family of LLMs trained for communications surveillance, trade
surveillance, and policy management. These models have been in production for
over three years and have passed dozens of model validation reviews. The
documentation that makes outputs explainable, transparent, and governable is
built in — not retrofitted. When compliance leaders ask us what happens when an
AI model is challenged in an examination, we can point to a production track
record rather than a promise.