Justin Ramirez

General Counsel & Chief Compliance Officer · Fintech · AI

Compliance as architecture, not process.

I run the legal and compliance function for a regulated fintech operating a FINRA broker-dealer, an SEC-registered investment adviser, and a futures entity, with hundreds of thousands of brokerage accounts supervised by a compliance team you can count on one hand.

That ratio works because I build. Over the past two years I’ve designed and shipped AI systems that run the firm’s compliance testing and ongoing supervision, and a framework that lets a large language model deliver investment advice that is deterministic, reproducible, and auditable, built for supervision under both the Investment Advisers Act and FINRA’s broker-dealer rules, and previewed with regulators before launch.

I call the operating philosophy supervision by design, the industry’s compliance-in-the-loop idea taken to its architectural conclusion: agentic systems do the data-pulling, formatting, and first-pass review; principals do the judgment work. The AI is never the decision-maker of last resort, and the architecture, not a policy binder, is what makes that true.

Flagship essay

How an LLM gives investment advice you can defend

Sanctioned channels, hard gates, and the audit trail as the unit of accountability: a deterministic framework for AI advice across the firm’s SEC-registered adviser and FINRA broker-dealer.

Operations

A supervision program that headcount can’t explain

AI-native compliance testing and surveillance, including a testing pillar that supervises the AI itself.

Method

Preview first. Surprise no one.

The regulator-first pattern: brief before launch, and show the architecture before anyone asks for it.