AI governance · AI security · Agentic AI

Governing AI before it governs you.

Your teams are already using AI — in products, in pipelines and, increasingly, as agents acting on your systems with their own credentials. The question your board, your customers and your regulators are asking is whether any of it is governed. We answer it from the CISO's chair: a governance framework people actually follow, and security controls that treat models and agents as what they are — new identities, new attack surface, and new things to monitor.

What you get

Three outcomes, each with a number on it.

Days 1–60

IP and code leakage stopped

Typically within sixty days: an inventory of every AI tool in use including shadow adoption, data classification and DLP applied to prompts, retrieval and code assistants, and an AI policy people can follow — so source code, customer data and trade secrets stop leaving through the side door.

Steady state

Two or three new models a week, governed

An AI Governance Council and review process sized to the real pace of adoption: intake, risk tiering, model cards and approval running as a weekly cadence rather than a quarterly bottleneck — so governance speeds the business up instead of slowing it down.

Agentic AI

Agents brought under control

The failure most organisations haven't seen yet: agents running on borrowed human credentials, with more privilege than any person would be given, acting across systems nobody scoped. We give every agent an identity, least privilege, scoped tools and a human-in-the-loop where it matters.

Alignment

Built to the standards assessors use

Everything maps to the EU AI Act, ISO/IEC 42001, the NIST AI RMF, the OWASP Agentic AI Top 10 and — for financial services — PRA SS1/23 model risk management from day one — so the ISO 42001 certification, the customer security questionnaire and the regulator's questions are answered by the same artefacts.

The engagement

Fixed scope. Typically sixty days, in three blocks of twenty.

A fixed-scope engagement, typically three twenty-day blocks with their own deliverables — so you know at the outset what you'll have at the end of each. Run to that shape, start to finish, for an FX trading firm and bank under PRA and FCA supervision. Delivered by a Global CISO who has built this as the accountable executive, not a bench.

Days 1–20 · Discover & protect

Find it, classify it, stop the leaks

AI and agent inventory including shadow AI · risk tiering of every use case · data classification and DLP on prompts, retrieval and code assistants · interim AI acceptable-use policy · landscape mapping: which laws and standards bind you, and the roles that carry each accountability.

Days 21–40 · Govern

Stand up the framework and the council

AI Governance Framework aligned to the EU AI Act, ISO 42001 and NIST AI RMF · AI Governance Council and AI Architecture Review Board with terms of reference and decision rights · AI policy · AI checklist for every new model and agent · model cards and AI registry · AI risk register and appetite.

Days 41–60 · Secure & operate

Control the agents, run the cadence

IAM for AI: an identity per agent, least privilege, scoped tokens and tool allow-lists, PAM for agents · SIEM for AI and AI detection & response · guardrails and prompt-injection defences · the weekly review cadence running at two or three models a week · handover, training and the ISO 42001 readiness position.

What you're left with

Artefacts your own team runs with.

FrameworkAI Governance Framework, including agentic AI, aligned to the EU AI Act, ISO/IEC 42001, NIST AI RMF and OWASP Agentic Top 10
GovernanceAI Governance Council and AI Architecture Review Board: terms of reference, decision rights, joint decision rights between CISO, CTO, DPO and CFO
Policy & processAI policy and acceptable use · AI checklist for every new model and agent · intake, risk tiering and approval process · incident response for AI
RecordsModel cards and AI registry · AI risk register and risk appetite statement · data retention for AI artefacts
SecurityAgent identity and least-privilege model · guardrails and DLP configuration · SIEM for AI use cases · AIDR playbooks and kill switches
ReadinessISO 42001 gap position and roadmap · EU AI Act operator classification and obligations map · board reporting pack

“An agent with a human's credentials and no human's judgement is the most privileged user in your estate. Most organisations have several and don't know it.”

— On why agents need identities of their own

Who this is for

Four people who tend to pick up the phone.

CTO / CIO

You want to move fast without a headline

Engineering is shipping AI weekly. You need a governance process that keeps pace — a review board that approves in days, not a committee that meets quarterly.

Board / investors

You want assurance you can rely on

A clear statement of AI risk appetite, an accountable executive, and evidence that the controls exist — in language the audit committee and a PE operating partner both accept.

CISO

You want a peer who's done it

Someone who has held the accountability, built the framework and argued it through with the CTO, legal and the DPO — to accelerate yours rather than start from a blank page.

Compliance / DPO

You want it to stand up to scrutiny

EU AI Act operator obligations, ISO 42001 readiness, GDPR Article 22 and sector rules — answered by one set of artefacts rather than four parallel efforts.

Secure, governed AI

What can go wrong when models act — and what stops it.

Agents don't just answer; they read, decide and act. That creates a threat surface most security programmes haven't mapped yet. This is how we think about it from the CISO's chair: eight ways agentic AI goes wrong — drawn from the OWASP Agentic AI and LLM Top 10 — mapped against the six NIST CSF 2.0 functions, with the controls we build under each, drawn from the NIST AI RMF and ISO 42001 — from an AI Architecture Review Board and model cards, through an identity for every agent, to SIEM for AI and recovery that can actually roll an agent back.

AGENTIC AI THREAT SURFACE What can go wrong when models act, not just answer Threats from OWASP Agentic AI & LLM Top 10 CONTROLS BY NIST CSF 2.0 FUNCTION → GOVERN Framework & policy (ISO 42001, EU AI Act) · AI ARB · risk appetite & tiering criteria · roles & accountability · acceptable use · board reporting IDENTIFY Asset & agent inventory · model cards · data-flow mapping · risk tiering · shadow AI discovery · plugin & MCP inventory · threat modelling PROTECT IAM for AI: identity per agent, least privilege, scoped tokens, human-in-the-loop, PAM · guardrails · prompt firewall · DLP on retrieval DETECT SIEM for AI: logging of prompts, tools, decisions & cost · telemetry · anomaly & misuse detection · AI detection & response (AIDR) RESPOND AIDR playbooks · block & decommission ungoverned AI · kill switches & agent quarantine · runbooks · tabletop exercises RECOVER Rollback of models, prompts & configs · clean restore of stores & state · identity re-issuance · ARB re-validation · degraded-mode fallback · migration off shadow AI Prompt injection direct, or indirect via documents, email, web pages and tool results Data leakage & exfiltration sensitive data pulled through retrieval, tools or model outputs Excessive agency agents taking actions beyond intent: payments, changes, deletions Identity & credential misuse agents acting as humans, over-privileged service identities, stolen tokens Model & supply-chain risk poisoned or unvetted models, plugins, MCP servers and datasets Insecure output handling generated code, SQL or markup executed without validation Shadow AI ungoverned tools and agents adopted outside any review Abuse & runaway cost model denial of service, loops, unbounded spend Primary control Supporting control GOVERNANCE LIFECYCLE · EVERY MODEL AND AGENT, BEFORE AND AFTER GO-LIVE Intake & use case › Identify & risk tier › AI ARB review › Model card & inventory › Identity & guardrails › Deploy › Monitor: SIEM for AI › Periodic review THREATS: OWASP AGENTIC AI & LLM TOP 10 · STRUCTURE: NIST CSF 2.0 · CONTROLS: NIST AI RMF · ISO 42001
Agentic AI threat surface: OWASP Agentic AI and LLM Top 10 threats mapped to NIST CSF 2.0 functions, with NIST AI RMF and ISO 42001-aligned controls. Hover or tap a threat to see its controls, or a function to see the threats it addresses. Click or tap the diagram to enlarge and zoom.

The AI governance landscape

The laws, standards, roles and controls your AI governance has to answer to.

Before a framework can be designed, the landscape has to be mapped: which regulations actually bind you, which standards an assessor will measure you against, who in the organisation carries each accountability, and the seven control domains every external reviewer expects to find. This is the anonymised map we start every AI governance engagement from; the detailed capability model and crosswalks behind it are built for each client.

Regulation

AI-specific law

  • EU AI Act (as amended by the 2026 Digital Omnibus) — prohibited practices; high-risk obligations; transparency and AI-literacy duties; post-market monitoring and serious-incident reporting; GPAI model obligations
  • US state law — Texas (TRAIGA), Colorado AI Act, California and sector-specific disclosure and review rules; federal AI Action Plan and state-law litigation to track
  • UK — regulator-led, principles-based approach; ICO AI guidance
  • Also in force or emerging: South Korea AI Basic Act · Japan AI Promotion Act · China GenAI measures · Council of Europe AI Convention

Related law

  • Privacy — GDPR / UK GDPR · CCPA/CPRA · DPDP · LGPD
  • Sector — e.g. HIPAA, FDA SaMD and MDR in health; FCA/PRA and DORA in finance; NIS2 and CAF for essential services
  • Employment — automated decision and bias-audit rules (NYC LL144 and successors)
  • Cyber & resilience — NIS2 · Cyber Resilience Act · DORA
Standards

ISO/IEC · CEN/CENELEC

  • 42001 AI management system — the certification anchor · 42006 auditor accreditation
  • 23894 AI risk management · 42005 impact assessment · 22989 terminology
  • 27090 AI security threat guidance · EN 18286:2026 EU AI Act quality management — first harmonised standard

NIST

  • AI RMF 1.0 (Govern · Map · Measure · Manage) + Generative AI Profile; mapped to 800-53 for US public-sector programmes

Principles & governance practice

  • OECD AI Principles · UNESCO AI Ethics · G7 Hiroshima Code · IEEE 2863-2026 organisational AI governance

AI security & secure engineering

  • OWASP LLM Top 10 · OWASP Agentic AI Top 10 · MITRE ATLAS · NIST AI 100-2 · ENISA
  • CISA/NCSC Secure AI System Development · NIST SSDF 800-218/218A · ISO/IEC 5338
AI
Governanceyour organisation
Roles

EU AI Act operators

  • Provider — you build AI into your own products
  • Deployer — you use third-party AI under your own authority
  • Importer / Distributor — usually not applicable; procurement flags exceptions to Legal

In the organisation

  • AI governance board or AI Architecture Review Board — cross-functional, with an accountable executive
  • Accountable executive — a Chief AI Officer, or the CISO or CTO holding that accountability
  • DPO — privacy and ethics authority
  • Model owners — lifecycle accountability per model and agent
  • CISO — AI risk and security authority · Internal audit — independent assurance (ISACA AI audit toolkit, IIA AI framework)
  • Joint decision rights where no single role decides alone: CISO + CTO on secure AI engineering · CISO + IT on enterprise control and shadow AI · CISO + DPO on personal data in AI · CTO + CFO on investment within risk appetite
Controls
AI inventory

Registry of every model and agent, including shadow adoption

Risk assessment

Tiering and impact assessment before deployment

Model assurance

Evaluations, red teaming, bias testing, model cards

Human oversight

Review, override and escalation of AI-influenced decisions

Agent controls

Agent identity, least privilege, tool permissions

Data controls

Classification, lineage, DLP, retention

Monitoring & audit

Logging, audit trail, SIEM for AI, incident response

AI governance landscape — regulation, standards, roles and control domains, anonymised. Click or tap the map to enlarge and scroll.

Recent mandates

Two sectors, one method — delivered as the accountable executive.

Recent mandates2024–2026
AI Governance Framework As fractional CISO for a start-up FX trading firm and bank: AI governance framework, AI Architecture Review Board, model cards and AI checklist covering AI in onboarding and KYC, fraud and customer service — aligned to PRA SS1/23 model risk management and FCA expectations. Delivered in sixty days, three blocks of twenty. FX trading & banking
AI Governance & Security As accountable executive for a PE-backed global SaaS group: enterprise AI governance framework including agentic AI, AI Governance Council, model cards, AI checklist and policy aligned to the EU AI Act and NIST AI RMF — plus IAM for AI, SIEM for AI and AI detection & response. ISO 42001 readiness established. Global SaaS

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