NEWWORK
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Financial Services · Spend & policy

Spend Control Under FINRA and MiFID

Testing every expense, gift, and entertainment against regulated-entity policy before it is approved, with audit-grade evidence attached to each decision.

What happens today

The policy is the point, not the amount.

In a regulated broker-dealer, bank, or investment firm, an expense is not only a cost. Client entertainment, a gift to a counterparty, or a political contribution can breach a FINRA rule, MiFID II inducement provisions, or the firm's own conflicts policy regardless of the dollar value. The control that matters is whether the spend was permitted, not whether it was cheap.

1

The rules differ by role, entity, and counterparty.

Limits and disclosures depend on who is spending, which regulated entity they sit in, who the recipient is, and whether the counterparty is a public official or a restricted party. The same dinner is fine for one desk and a reportable event for another, and the person submitting it rarely knows which.

2

Approvers see the claim, not the rule.

The manager approving an expense seldom has the specific limit, the cumulative gift-log history, or the conflicts register in front of them. So the check is either waved through on trust or sent back for manual research that no one has time to do before month end.

3

The evidence is assembled only when someone asks.

When compliance or an examiner asks why an expense was approved, the answer is spread across the expense system, an email thread, and a spreadsheet gift log. Reconstructing it after the fact is slow, and a thin record is exactly what an examination flags.

How the architecture runs it

In a regulated firm an expense is a policy question, not a cost one, and the rule that applies depends on who is spending, in which entity, to whom. The FLOW derives the test for each claim, checks every line against the limits and the gift log and the conflicts register, passes the clean ones, and sends only genuine exceptions to compliance with the failed rule attached.

Policy

the compliance team owns the limits, the gift and pre-clearance rules, and the restricted parties, in plain text

Agent Human
1
Connect
Claim submitted role & entity
2
Business Context
The rules that apply resolved for the claim
3
Digital Task Agent
Tested against every rule at once
Every rule, tested in parallel
Spend & gift limit
Cumulative gift-log total
Conflicts register
Restricted party & PEP
Pre-clearance & disclosure
Digital Supervisor
Control gate pass every rule, or route the exception
passes needs sign-off breach
4
Connect
Approved & booked written to finance
5
Enterprise Workplace
Routed for approval owner decides
5
Enterprise Workplace
Blocked & held for compliance
Every step logged
Execution record

every claim: the rule it was tested against, the value that failed it, the outcome, and who decided

Audit-ready

What the FLOW does

1

Trigger on submission.

An expense submitted in the finance system starts the FLOW; Connect pulls the claim, the submitter’s role and regulated entity, and the counterparty from the systems that hold each.

2

Resolve the policy.

Business Context reads the limits, the disclosure and pre-clearance rules, and the restricted-party checks the compliance team owns, and resolves which of them apply to this submitter, entity, and recipient, so the exact test is derived for the claim rather than left to an approver to remember.

3

Test every line.

A Digital Task Agent validates the claim against the limits, the cumulative gift-log total, the conflicts register, and any pre-clearance requirement, flagging each anomaly with the rule that failed and the value that failed it.

4

Approve and book the clean claims.

A claim that clears passes straight to approval, and Connect writes it back to the finance system with the gift log updated, so the next review validates against current figures.

5

Hold the exception for compliance.

A genuine policy exception goes to the compliance owner in the Enterprise Workplace, or is blocked and held, with the claim, the failed rule, and the history already attached, so the human makes a judgment rather than assembling the context for one.

What it's worth

Different decision-makers weigh different things.

Here is what this FLOW returns to each.

CFO

Spend tested against policy before it is approved, so breaches are prevented rather than remediated, and the hours spent researching limits by hand come back.

COO

Clean claims clear straight through and only real exceptions stop for a person, so approvals stop stalling the month-end close.

Board & Risk

Every expense, gift, and entertainment tested against the rule that applies to that role, entity, and counterparty, with a defensible record of each call.

CIO

Runs above the expense and finance systems with no migration; the limits and rules stay business-owned, the tool bounds IT-owned.

CCO

The gift log and conflicts register stay current, so a FINRA or MiFID examination reads the record of why a spend was approved instead of a reconstruction.

Coexistence

How this connects to what you already run.

NEWWORK Connect reads from and writes to the systems that run the bank, including core banking, CRM, finance, case management, and screening tools. Those systems remain your Systems of Record. NEWWORK runs above and between them, which is why a FLOW of this kind can go into production without a migration program standing in front of it.

You can begin with one of these FLOWs, with a Digital Employee owning a single recurring role, with an Enterprise Workplace for one function, or with a complete Business Solution. Any starting point. Any combination. Your way.

Start above your existing systems. Replace selectively when it creates value.

Governed autonomy

Why the record matters as much as the work.

Every FLOW produces one execution record: what happened, in what order, under which policy, by which human or which Digital Task Agent, on what evidence, and with what outcome.

Governed autonomy means the FLOW acts inside limits you set, escalates what it should not decide alone, and leaves a trace of both. The same record answers the examination, the complaint audit, and the SAR review, because it is the record of the work itself rather than a report written about it afterward.

That is what makes work of this kind safe to give to an AI system in an examined, regulated business, where identity, approval, audit trails, and human oversight have to be visible before anything moves into production. The capability is what makes the pilot worth running. The record is what makes it defensible.

AI-native by architecture. Agentic in execution. Autonomous where governed.

Next step

Bring us your requirement set.

The fastest way to judge this is against your own rules. Bring one expense policy, one escalation path, or a sample of alerts, and we will show the FLOW resolving it end to end — including where it stops and asks a human.