The adequacy of a compliance organisation is not a static concept, but is assessed as part of a continuous, due diligence-based weighing up of costs and benefits based on a risk analysis. This is where technological change comes into play, constantly expanding the range of options. Advances in what is technically feasible and falling technology costs are gradually shifting the framework conditions. What was considered a disproportionate burden yesterday may become a legal obligation tomorrow.
To keep pace with this development, compliance officers should continuously monitor technological developments. In particular, the use of AI can help identify potential risks at an early stage – before they develop into concrete findings, incidents or even regulatory proceedings. This is where the HM Argus Reviewer comes in.
From ad hoc checks to reliable risk detection
The HM Argus Reviewer replaces ad hoc checks with a continuous, predictable and rule-based analysis. Relevant documents – such as newly received emails in high-risk areas or files stored in specifically defined locations – are regularly reviewed against a predefined, legally vetted and broadly agreed set of compliance questions. The frequency of these checks can be freely determined, for example on a weekly or monthly basis. The range of possible applications extends from fully automated checks to the monitoring of entire folder structures. Documents identified as relevant are forwarded – immediately or periodically, as required – to the relevant audit or specialist departments for verification, ensuring that the final assessment is always carried out by a human decision-maker, the so-called “human in the loop”.
Identifying what traditional controls overlook
HM Argus utilises both semantic and language-independent text analysis, enabling it to reliably identify even implicit or previously unknown risk patterns. This opens up previously inaccessible areas of data within organisations where traditional, predominantly keyword-based control systems often fail. In previous investigative use cases, the system achieves a recall rate of over 90 per cent of all relevant documents and, on a systematic level, reduces the risk of overlooking critical issues. This also applies in cases where compliance controls are required across regulatory frameworks, languages and markets: the reviewer is configured for specific domains and its scope of application is freely configurable. Scaling can be achieved without the need for additional staff, as growing data volumes and regulatory requirements are explicitly managed by the technology rather than through increased headcount. The result is reduced review workloads, faster case processing and lower liability and reputational risk, alongside improved traceability, governance-related issues and decision-making.
Legal framework in focus
The use of an AI-powered compliance tool raises several legal issues. These relate, among other things, to communication with employees regarding the use of the tool, the involvement of the works council, data access in compliance with data protection regulations, and the introduction of the tool within various legal frameworks, such as those defined at national level. We will explore these topics in a separate blog post.
Technology and operations
The HM Argus Reviewer is provided as a containerised standard solution and can run in virtually all client environments. The operating model is flexible, meaning that the Reviewer can be operated both within the client’s own IT environment and on Hengeler Mueller’s systems. As part of a comprehensive onboarding process, (partially) automated interfaces to the client’s individual systems are established in collaboration with the user. The language model used is also the result of a joint decision. The options range from cloud models controlled by Hengeler Mueller to cloud or on-premises models already in use at the client’s site. Furthermore, HM Argus Reviewer provides for further customisation to suit the client’s specific needs: prompt specialists from Hengeler Mueller translate the client’s specific review questions into targeted, model-optimised prompts, whilst ongoing adjustments are also carried out in a structured and documented manner, in close cooperation between the client company and Hengeler Mueller.
Hengeler Mueller can provide legal and technical expertise not only for the implementation but also for the ongoing operation of HM Argus Reviewer, tailored to the scope required by the client and the degree of customisation. This ensures that compliance does not remain a one-off project but becomes a firmly established practice within the organisation.
