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Building safety by design: How FinLLM makes architectural choices that matter

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by Aveni
| 20/07/2025 18:00:00

The urgency behind responsible AI in finance

UK financial services firms are rapidly adopting Large Language Models (LLMs) as they look to reduce operational costs, enhance customer experience, and meet increasing regulatory demands. Beyond back-office automation, these technologies hold real potential to close the long-standing advice gap by delivering affordable, scalable support. 

At the same time, challenger banks and fintechs, unburdened by legacy infrastructure, are accelerating innovation. In this context, adopting LLMs is no longer experimental; it is essential for firms aiming to remain competitive and resilient in a fast-evolving market.

However, these benefits come with risks. While LLMs are powerful, they are far from perfect. Without appropriate safeguards, they can hallucinate facts, expose sensitive data, or reflect embedded biases.  These issues can carry serious regulatory and reputational consequences across all financial services operations. In such a tightly governed sector where every transaction and interaction carries inherent risk, it is imperative to adopt foundation models embedded with a structured risk framework.

At Aveni, we prioritise safety and compliance throughout the development lifecycle, implementing industry-leading AI governance practices inspired by the EU AI Act and guidance from the FCA and Bank of England. From responsible data sourcing and training to rigorous evaluation and continuous monitoring, we ensure transparency and domain relevance at every stage. While no AI system is entirely risk-free,  we help firms navigate and optimise trade-offs, balancing performance with control, and innovation with accountability. 

The path forward for LLM adoption is not about perfection (humans make mistakes too) but about delivering measurably better outcomes for more people, backed by robust safeguards. Aveni’s approach works within established regulatory and ethical boundaries, ensuring that solutions are not only performant but also trustworthy, resilient, and fit for purpose in impactful financial applications.

Understanding the real-world risks of LLMs in finance: 

Risk
 
What can happen?
 
Finance sector impact
 
Real-world example
 
How FinLLM mitigates this
 
Hallucination and misinformation LLMs may fabricate facts, laws, or financial guidance with confidence. Whilst designed to be creative, inevitably they can also go off on a tangent. False or misleading information can lead to poor financial decisions, regulatory breaches, or loss of trust. A chatbot tells a customer they are eligible for a tax-free ISA allowance twice in one year, leading to penalties.

Retrieval-Augmented Generation (RAG): FinLLM grounds responses in verified, real-time financial data sources rather than relying on “memory.” Industry-specific reinforcement learning with continuous auditing by financial experts ensures accuracy. Finance Classifier 2.0 filters training data to prioritise high-quality regulatory guidance and financial literature.

Data Privacy and confidentiality  LLMs may inadvertently retain and echo sensitive data from previous sessions or their training data. Breach of client confidentiality, GDPR violations, and reputational damage. A client-facing AI tool mistakenly outputs snippets of another customer’s mortgage application during a live support session.

Privacy controls built into the foundation: Every piece of data is scrubbed and verified before entering the system. Forensic-level interaction tracking ensures complete visibility over data flow. GDPR-compliant architecture prevents data leakage between sessions or clients.

Copyright infringement LLMs may reproduce copyrighted content without attribution or permission, and undermine the original publisher’s business model by redistributing protected content. Legal risk for firms; reputational damage; content takedown or financial penalties.

An LLM response contains a verbatim paragraph lifted from a Bloomberg article, including proprietary analysis and paywalled commentary. The response is then shared with clients via an internal report.

Licensed, auditable training data: FinLLM uses only properly licensed financial data sources. Transparent data lineage allows firms to trace and verify the legal rights to all information used. Source attribution capabilities built into RAG framework enable proper crediting.
Bias LLMs trained on skewed datasets may produce biased recommendations. Discriminatory lending or investment advice, breaches of fairness rules, regulatory scrutiny. A creditworthiness assessment tool subtly downgrades applications from certain postcodes historically linked with lower-income areas, violating fair lending rules.
 

Precision bias engineering: Training data is stress-tested for bias, not just scanned. Real-time output monitoring with continuous measurement of fairness improvements. Human feedback integration aligns outputs with FCA values and ethical requirements while maintaining performance.

Toxicity LLMs trained on vast amounts of data collected from the web may output toxic responses, mimicking segments of the training data.. Reputational damage; negative impact on staff/customers wellbeing. An LLM-powered chatbot outputs responses to customers that contain e.g. sexist or racist language.

Pre-training data filtering: All training data undergoes filtering to flag sensitive, toxic, and biased content before the model processes any tokens. Ethics by design with guardrails reflecting values of fairness, transparency, and responsibility. Curated financial datasets eliminate toxic web content entirely.

Lack of explainability LLMs often do not (or cannot) justify their answers, or fail to do so in human-understandable ways. Customers and regulators cannot assess why a recommendation was made.

 

 

A digital advice tool denies a user an investment option with no clear reasoning—undermining trust and failing to meet regulatory expectations for suitability explanations.
 

Built-in transparency: FinLLM tracks where answers originate and presents information in structured, auditable formats. Source traceability through RAG framework allows teams, customers, and regulators to understand decision-making processes. Court-room ready explanations designed for regulatory scrutiny.

Over-reliance by advisers or customers Users may take LLM outputs as authoritative, bypassing compliance checks or expert review. Mis-sold products, customer detriment, and breach of regulatory duties (e.g., Consumer Duty in the UK). A junior adviser uses an LLM to draft a pension switch recommendation without realising it includes incorrect comparison data, leading to mis-selling.

Human-in-the-loop design: FinLLM is built to enhance human judgment, not replace it. High-stakes decision flagging ensures critical choices require human review. Clear uncertainty communication prevents over-confidence in AI recommendations. Compliance safeguards maintain adviser control over final decisions.

Jailbreaks LLM safety controls may be bypassed via specially crafted prompts or manipulations. Unauthorised financial advice, misleading product suggestions and data breaches. Vulnerability in a mortgage processing LLM allows extraction of applicant financial data through specialised prompting. Multi-layered security architecture: Input/output guardrails prevent prompt manipulation. Comprehensive InfoSec regime with secure data handling practices. Future-proofed safety measures including planned response justifications to meet evolving regulatory expectations. Continuous monitoring for attempted security bypasses.

 

These risks, if not addressed early, can impact everyone including customers, employees, firms, and even content owners. Even more, the initial impact often snowballs into larger consequences.  That is why FinLLM is built with deliberate design choices to mitigate these risks from the ground up.

Base model selection
We take a transparency approach right from the beginning, starting with the models we choose to build on. To make smart, informed decisions, we created a scoring system that helps us evaluate different model families against 10 key transparency criteria inspired by the Foundation Model Transparency Index which includes training data transparency, training process disclosure, licensing openness and safety benchmarking.

Responsible and transparent data collection
It all starts with data. FinLLM is constantly being pre-trained on AveniVault – our custom-built, finance-focused dataset made up of responsibly sourced, publicly available content. We stick to strict data governance standards, making sure everything we use complies with copyright rules, avoids toxic content, and respects opt-out requests. Where needed, we license proprietary data directly, and we also generate synthetic data to strengthen coverage in key financial areas. To expand our finance training corpus, we developed a custom classifier that accurately filters and tags general financial text with high relevance—enabling more efficient scaling of domain-specific data for LLM training.

Evaluation 
Evaluation is key to measuring model performance. We evaluate all models using AveniBench, our bespoke benchmark which includes use-case relevant finance-specific, general, and safety datasets to assess both performance and risk. Our safety evaluations zero in on the big risk areas like hallucinations, bias, toxicity, privacy breaches, IP issues, and jailbreak vulnerabilities. This helps us spot and fix problems before anything goes live. 

We use AveniBench, our own custom evaluation framework, which is constantly evolving to stay aligned with client needs. It brings together the most reliable and relevant datasets out there, from both the open-source community and our own bespoke collections, to make sure we are testing against real-world scenarios that matter.

Additionally, we have embedded the following essential architectural design attributes that support the responsible development and deployment of our models. 

  • Use of domain specific, fine tuned models 
    FinLLM is not a single general-purpose model, but a suite of domain-specific, fine-tuned LLMs. Each model varies in size, transparency, and capability to align with different use cases, whether focused on tabular data, financial reasoning, or summarisation. This reduces dependency on large, opaque foundation models and enhances safety, performance, and control.

  • Guardrails and filtering
    Guardrails act as safety filters between the model and the end user, preventing exposure to harmful, biased, or sensitive content. In FinLLM, we embed these controls early in the data pipeline, using comprehensive filtering to detect biased, toxic language and personal data, aligned with ICO guidance. Where needed, anonymisation is applied to protect privacy before training. Guardrails are also applied on model input and outputs to ensure safe responses to users. 

  • Prompt engineering
    Prompt design directly shapes model behaviour. Standardised, well-tested prompts reduce variability, keep output aligned to tasks, and guard against prompt injection. In FinLLM, we work with subject matter experts to tailor system prompts based on user personas, workflows, regulatory constraints, and brand tone—ensuring each model is aligned to the environment and task it serves.

  •  Retrieval-Augmented Generation (RAG)
    Retrieval-Augmented Generation (RAG) grounds model outputs in real-time, trusted data, reducing hallucinations. In FinLLM, our RAG layer ensures responses are based on up-to-date, customer records, product-specific information or internal vetted sources rather than static training data—critical for accuracy in financial use cases.

  • Alignment layers (e.g. RLHF)
    Techniques like reinforcement learning from human feedback (RLHF) help align LLMs with human expectations, ethical standards, and business values. These post-training adjustments teach the model to behave in a more predictable and human-like way. In FinLLM we have identified training and evaluation datasets which will teach our models these human values.

  • Explainability 
    Explainability features help trace the steps that a model took to reach its output, supporting auditability and accountability, especially in regulated environments. In FinLLM, this includes attribution in RAG (e.g. linking responses to source documents) and traceability in classification tasks, such as highlighting specific points in a call transcript where customer vulnerability was detected.

  • Audit logging and traceability
    Right from the start, FinLLM has embedded good practices of maintaining comprehensive logging of user inputs, model responses, user IDs, and model versions to  support active monitoring of models during deployment for potential performance drift and/or safety degradation—particularly under regulations like SS1/23 and the EU AI Act.

  •  Continuous monitoring and feedback loops
    LLM deployment risk varies by use case, and many clients will choose to adopt a co-pilot approach to maintain control. For each use case, we complete a Responsible AI User Impact Assessment to consistently assess and define its intended use, risk level, and acceptable outcomes, guiding the level of validation and monitoring required. Where appropriate,  we embed human-in-the-loop steps to review outputs (e.g. summaries, recommendations) for accuracy, IP risk, or to enable feedback for iterative  improvement.

What responsible AI looks like in practice

Responsible AI is not just about what a model can do—it is about how it is built and governed. In finance, where the stakes are high, foundation models bring huge promise. But tapping into that promise safely demands:

  • Thoughtful design
  • Multi-layered defense mechanism
  • Clear trade-offs
  • Continuous oversight
  • Iterative development 

That is exactly what we have embedded into FinLLM, from domain-specific architecture and responsible data sourcing to rigorous evaluation and safety-first deployment. With new techniques emerging rapidly, we can not afford to stand still. At Aveni Labs, we stay ahead by collaborating with the University of Edinburgh and tracking the AI research community, applying the latest insights, data, and training methods to our work. 

Following up with a four-part technical series, we will take you behind the scenes of FinLLM to show how safety and governance are built into every layer of the model lifecycle. From responsible data sourcing to alignment, rigorous evaluation, and real-time guardrails at deployment—we will explore how each stage is engineered for trust, control, and compliance.

Read the original article here.