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.

New writing · FINRA panel

Govern what the AI does.

A practical, three-tier framework for GenAI governance, developed for my September 22 panel at FINRA’s Midwest Region Member Firm Forum.

Read the article →

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.

Beyond the work

Training, flying, teaching.

Daily triathlon training, a private pilot certificate and a Piper Cherokee, and guest lecturing at Rowan University.