Can an AI worker handle client money or make payments?
No. An AI worker never moves money. It does the work around it: reminders, matching and files ready for approval. A named person pays and signs off.
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5 minute read
No. An AI worker never moves money: it does not pay a supplier, release a deposit, take a card payment, send a refund or change anyone's bank details. What it can do is the work around the money: the reminders, the matching, the chasing and a file ready for a person to approve. Where the money belongs to your clients, the rules put the responsibility on named people, and that is where it stays.
What the rules say about money you hold for other people
The rules differ by profession and by nation. These are two, as the regulator, GOV.UK and mygov.scot state them. How your firm complies is for you and your own advisers.
Letting and property management agents. In England an agent in the private rented sector that holds clients' money must join a client money protection scheme, and must hold that money in an account with a bank or building society authorised by the Financial Conduct Authority. The fine for not joining is up to £30,000. In Wales an agent joins a scheme before applying for a licence through Rent Smart Wales. In Scotland an agent must hold professional indemnity insurance, and one that holds client money also needs client money protection insurance and a separate client account. Northern Ireland does not require an agent to join a scheme.
Solicitors, in England and Wales. Under rule 5.1 of the SRA Accounts Rules, client money leaves a client account only for the purpose for which it is held, on instructions from the client or the third party it is held for, or on the SRA's prior written authorisation or in prescribed circumstances. Under rule 5.3 sufficient funds must be held for that client or third party. Under rule 5.2 the firm must "appropriately authorise and supervise all withdrawals made from a client account". Under rule 8.3 every client account is reconciled at least every five weeks, and the record is signed off by the firm's compliance officer for finance and administration (the COFA) or by a manager of the firm.
If your firm holds client money under another regulator, its rules, and the people they name, decide who authorises a payment.
Why the answer is never, and not "with approval"
Most of what an AI worker does can wait for a person's approval and then run. Payments are different, for three reasons.
A payment cannot be undone. A wrong entry in a system is put right in a minute. Money sent to the wrong account may not come back.
Fraud arrives as a convincing message. The usual attempt is an email that looks like a supplier, a landlord or a director asking for a payment or for new bank details. A worker with no way to pay and no way to edit bank details cannot be talked into either.
Whoever prepares a payment should not be the one who makes it. An AI worker sits on the preparing side of it for good.
So the line is drawn in what the worker is given, not in what it is told. It has no access to your bank, your payment run or your card terminal, and no permission to change bank details on a record.
What an AI worker can do around the money
Each job is written down, with a named person who checks the work. Around money, the jobs that fit are these:
Chasing invoices and rent: reminders in wording you approved, at the intervals you choose, copy invoices and statements sent on request, every reply read and each promised date logged and checked.
Preparing purchase invoices: read, matched against the order and the delivery note, coded, with duplicates and mismatches listed for the person who approves.
Spotting the risky message: an email asking to change bank details is passed to a person as exactly that. The worker does not act on it.
Answering the routine question, such as whether an invoice has been received, from what the ledger shows and in wording you have approved.
Every one of those actions is logged, so the person approving a payment can see what was checked and what was not. How those roles apply to letting agents and law firms is set out on their own pages.
What stays with a named person
Every payment, refund and transfer, and the approval of every payment run.
Releasing a deposit or paying a landlord.
Any change to a supplier's, client's or landlord's bank details, verified by a person in the way your firm requires.
The client account reconciliation and its sign-off. In a law firm in England and Wales that is the COFA or a manager, by rule.
Payment plans, disputes, write-offs and anything formal about a debt.
Access to the bank itself.
What depends on your own policies and on the contract
Who may approve a payment and up to what amount, and how a change of bank details is verified, are your firm's own controls, and an AI worker is fitted around them. What the worker may never do should also be written into your contract with whoever provides it, so that it is a term and not a setting.
Questions to ask any provider
Does the worker have any access to our bank or payment run? The answer should be no.
Can it create or edit bank details on any record?
What does it do with an email asking for a payment or a change of account?
Can our approver see the log of what it checked on each invoice?
For a firm that holds other people's money, the worker would chase, match and prepare, and your people would approve every payment, release every deposit and verify every change of bank details. The reminders and the matching are the hours to hand over. Talk to our agent.
Carlos Oliveira
Founder of The AR Dept
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