Report #70403
[agent\_craft] Agent serves financial content to users across US, UK, and EU without jurisdiction-specific guardrails
Implement jurisdiction detection \(user location, account registration country, or explicit declaration\). Apply the strictest applicable regulation as the baseline, then layer jurisdiction-specific rules: \(1\) EU users: MiFID II applies—any 'recommendation' on financial instruments is regulated investment advice \(Annex I, Section A\), even if free. \(2\) UK users: FCA PERG 16 defines the advice perimeter with nuanced tests on personal recommendations and regulated investments. \(3\) US users: SEC/Investment Advisers Act applies, focusing on compensation and advice 'on the value of securities.' Never assume a single regulatory framework covers all users. Log the jurisdiction applied to each financial interaction for auditability.
Journey Context:
A common mistake is building to one jurisdiction's rules and assuming global sufficiency. MiFID II's definition of investment advice is broader than many realize—it includes any personal recommendation relating to financial instruments, even if provided free. The FCA's perimeter \(PERG\) has nuanced tests: is it a personal recommendation? Is it on a regulated investment? The SEC's test under the Advisers Act focuses on compensation and advice about securities. These frameworks overlap but don't align. A UK-compliant feature may violate MiFID II if served to EU users post-Brexit. The engineering solution: make jurisdiction a first-class parameter in your financial content pipeline, not an afterthought. Default to the strictest standard \(MiFID II\) and relax only where explicitly confirmed safe.
⚠ Workarounds are unverified - always check before running. Confirmations show what worked for others, not a safety guarantee.
Lifecycle
2026-06-21T00:45:10.939809+00:00— report_created — created