Compliance

For compliance teams

Compliance officers, allocators, and operational due diligence teams.

Where do the numbers come from? And what leaves our firm? The list of limit breaches answers with the figure, the acknowledgement record and the audit stamp. A trader commits a plan to confirm it as the plan of record. Every committed plan is recorded in an audit trail. So is every limit breach found with it, and each time an officer acknowledges one. Nothing is reconstructed after the fact. The audit log and acknowledgements are append-only: DojiPad can add to them but can't change them. Plans and their limit checks can still be edited, and anyone with the database password can change any record, so database access belongs under your firm's controls. How long you keep records is your firm's policy.

How is the use of AI governed, and how is that shown? With a record you can hand over, not a paragraph of policy. The regulatory and operational due diligence (ODD) material is in the Regulation section of this page.

On this page

  1. 1 Your compliance framework What DojiPad adds to the checks you already run, and what it doesn't replace. →
  2. 2 What DojiPad records The plan, any limit breach and its figures, what the trader was shown, acknowledgements, sign-offs and export stamps. →
  3. 3 Your firm's limits How your firm's limits are loaded, encoded, switched on and versioned. The system refuses to guess. →
  4. 4 Audit trail Limit breaches, an acknowledgement record that can only be added to, daily sign-offs, stamped PDFs. →
  5. 5 Your obligations What DojiPad adds to your obligations, and what it doesn't. →
  6. 6 Regulation EU AI Act, SEC record keeping, allocator due diligence: what each asks and what DojiPad does. →
  7. 7 Regulatory memo Request the regulatory alignment memo your compliance team can file. →
  8. 8 Security review What a review under NDA covers. →
  9. 9 Due diligence Questionnaires, security reviews, audit access and company details. →
  10. 10 What it does not do In the product's own words, from its own screens. →
  11. → Pilot 30 days from go-live, on one desk, in your firm's own cloud account. The fee is credited in full if you go on to subscribe. →
  12. → Request a briefing DojiPad running live on a simulated firm. We show it first from the list of limit breaches, then from the trader's side. →

How it fits your compliance framework

DojiPad doesn't replace the pre-trade checks in your order system or your post-trade surveillance. It adds what neither holds: a record of the decision itself, made at the time and checked against your limits, before the order.

What DojiPad records

  • the committed plan and its written reasoning;
  • for a plan that would breach a limit: the figure, the limit, the price used and what it was measured against;
  • what the trader was shown: the full figure, only whether they were near or over the limit, or nothing (a limit monitored internally);
  • acknowledgements, append-only: who reviewed which breaches, and when;
  • daily sign-offs;
  • a stamp on each export (see the stamp). Opening any page that can be exported is logged as an audit event.

Product · Your firm's limits

How DojiPad sets up your firm's limits

We set up your limits from your own documents, in two workshops with your risk or compliance owner. Limits that can't be written as rules are listed as not monitored, never silently skipped. If DojiPad can't map an instrument, it says so rather than guessing. Each limit is set to show traders the full figure, only whether they are near or over the limit, or nothing (monitored internally).

I.

From your limit document to proposed limits

You give DojiPad the document that sets out your firm's limits. DojiPad proposes each limit, ready to be set up in the system. Each limit's threshold, and what it is measured against, must come from the document's own text. If they do not, the proposal says the limit cannot be expressed. It never shows a guessed number. DojiPad does not guess.

II.

Versions, switching on, and what is monitored

Each limit, once set up, is either switched on or not. When a limit changes, the old version is kept, and each limit finding records which version it was checked against. Every exported PDF carries a stamp. The stamp lists which limits are monitored and which are declared not monitored. So a gap in coverage is stated openly, never left unsaid.

III.

Plans that cannot be measured are refused

Futures are sized in contracts, using a verified record of contract multipliers. A plan that cannot be measured this way is refused, not estimated.

IV.

In the walkthrough

Recorded on the live product. The chapter on the firm's limits shows the list of limits for Aurora Capital Management (Simulated). One of them is not yet set up. Every figure on screen is calculated from the records at the moment the page is requested.

Product · The list of limit breaches

The list of limit breaches and the audit trail

Risk and compliance read this page first. The list of limit breaches is where your firm keeps the figure. It shows three separate states. It keeps an acknowledgement record that can only be added to. It runs a daily sign-off. And it stamps everything it prints.

I.

Grouped by trader and limit, repeat breaches first

Each group shows its worst breach, as a multiple of the limit. Three states are kept separate because they answer different questions. Open is the firm's state: a limit breach that no one has acknowledged yet. Unreviewed by you is this officer's own marker: what has arrived since this officer last looked. Acknowledged is the acknowledgement record: reviewed, on the record, with a name and a time.

Session monitoring is not active — no execution feed is connected. Silence here is not a clean bill.
Redrawn from the live product for this site. Figures are live values from Aurora Capital Management (Simulated).
Limit breach
Up to 1.71× the limit
Emre Sato (Simulated) · Systematic desk
26 breaches · first 30 Aug 2026, 18:30 UTC · latest 30 Aug 2026, 22:41 UTC · 22 open · 4 acknowledged · 1 unreviewed by you
Redrawn from the live product for this site. Figures are live values from Aurora Capital Management (Simulated).
II.

Acknowledging a breach does not delete it

Every acknowledgement is saved with the officer's name, the time, and the limit breaches it covers. Entries can only be added, never changed: DojiPad can't edit or remove one.

Acknowledgement record
Limit breaches acknowledged
10 breaches · Kofi Petrov (Simulated)
Acknowledged by Compliance officer (Simulated)
31 Aug 2026, 19:31 UTC
Redrawn from the live product for this site. Figures are live values from Aurora Capital Management (Simulated).
III.

The daily sign-off

Every day, the system checks every active limit for every trader. Each result is one of three: within the limit, breached, or declared not measured. A limit that could not be measured is listed as not a pass. So the gap is visible, not silent.

IV.

Every printout names what it covers

Every oversight screen can be printed to PDF. Each PDF shows the as-of time and the officer who generated it. It shows the filter it was printed with (desk, name filter, status). And it carries the monitoring line, which names any limits that are not monitored.

As of 2 Sep 2026, 00:46 UTC · view: desk
Scope: whole organisation.
Generated by Compliance officer (Simulated)
Monitoring: 6 of 20 clauses monitored.
NOT MONITORED at generation: 7.2 (unevaluable_stale_nav); 9.4 (unencoded); 9.7 (unencoded) (list truncated for this rendering; the export names every desk's clauses)
Redrawn from the live product for this site. Figures are live values from Aurora Capital Management (Simulated).

See the stamp box on a desk overview export →

V.

An open flag means the same everywhere

Open means a limit breach that no one has acknowledged. The list of limit breaches, the desk overview and Analytics all show the same number.

VI.

One filter bar on every oversight screen

Every oversight screen has the same filter bar: one desk or the whole organization, a name search, and status. The filter travels with the record. It is stamped on the PDF, so a filtered export says that it is filtered.

What it adds to your obligations, and what it doesn't

  • We never hold your trade data: DojiPad runs in your firm's own cloud account, and nothing in it calls back to us.
  • It doesn't sit in your execution path: it never touches an order.
  • The trader's conversation with DJ, DojiPad's AI coach, is kept off the firm's screens by design: the firm's screens and reports can't retrieve the trader's side. It is stored in your firm's own database, so, as with any system your firm hosts, its database administrators could read it there. The firm's record is the committed plan and any limit breach found with it. Our regulatory memo sets out how we see that against recordkeeping rules; your counsel should confirm it for your firm. Paper III explains why this makes a better record.
  • It does add a record you can show: the decision, the check and the review.

Regulation

What regulators and allocators ask

We do not ask your firm to trust a young vendor on faith. We also do not hand over our technology to prove ourselves. Instead, we show where the rules are heading, and what the system already does for each. The full mapping is available as a memo. The architecture is reviewed live with your firm's security team under NDA.

I.

Three sets of rules, and what DojiPad does

EU AI ACT Regulation (EU) 2024/1689 · Since the AI Omnibus entered into force in July 2026, high-risk obligations for standalone systems apply from 2 December 2027. Status as of October 2026.
What the law asks: AI systems that affect important decisions must have risk management, logging and human oversight. They must be transparent to the firms that deploy them, and they must keep records. What DojiPad does: every interaction with the AI model that produces an oversight record is logged, and the log can only be added to. A person makes every trading decision, by design. Your firm can audit every prediction the system makes, and how each was graded, inside your own environment. The documentation is written for your firm's own conformity work under the Act.
SEC RECORD KEEPING Exchange Act Rule 17a-4 as modernized October 2022 · Advisers Act Rule 204-2(a)(7)
What the rules ask: electronic records must be kept in systems that allow viewing, download and audit. Communications about recommendations and advice must also be kept. Enforcement has been widening what counts as such a record since 2022. What DojiPad does: it keeps an audit trail for every decision, inside the private copy of DojiPad in your own cloud account. The audit trail can be exported. It stays in your firm's own storage, under your firm's retention policy. Its format is built for an examination, not reconstructed for one.
ALLOCATOR DUE DILIGENCE (ODD) AIMA DDQ standard · AI governance now on most institutional checklists (industry ODD analyses, 2025)
What allocators ask: does the manager have a formal policy on using AI in the investment process? And how is that use governed and shown? What DojiPad provides: the answer, as a record you can hand over. A documented approach to governing the system. Separate oversight screens for each role. And a record, made at the time, of every committed plan and every limit breach found with it, before the order. None of the controls you already run (order checks, surveillance, P&L review) can produce that record.

Bloomberg and Charles River do not publish how their systems work inside, and neither do we. A serious vendor does not owe a serious client its source code. It owes evidence that it understands the obligations the client actually carries. And it owes a system already built around them.

II.

The regulatory timeline and the allocator question

FROM OUR RESEARCHDECISION RECORDS AND AI GOVERNANCE
OCT 2022The SEC adopts amendments that modernize electronic recordkeeping under Exchange Act Rule 17a-4. Records must be kept in systems that allow viewing, download, and audit.
2022 ONWARDThe sweep on off-channel communications begins: eleven orders in September 2022, and billions in penalties across the industry since. Advisers Act Rule 204-2(a)(7) requires firms to keep communications about recommendations and advice. Enforcement has made one question a board-level matter: where a record of advice begins and ends.
AUG 2024The EU AI Act, Regulation 2024/1689, enters into force. It is the first comprehensive framework for AI that applies across all sectors. Its duties on logging, transparency, human oversight, and record keeping phase in by risk tier.
DEC 2027Since the AI Omnibus entered into force in July 2026, high-risk obligations for standalone systems apply from 2 December 2027. Status as of October 2026. For AI built into regulated products, they apply from 2 August 2028. Either way, firms that use AI in consequential decisions face duties on documentation, oversight, and logging.

The direction is clear. Regulators increasingly expect a record of how decisions are made, not only of what was executed. They also expect governance of any AI that touches those decisions. A record made before the order, created and kept inside your firm, is built for exactly this direction.

SOURCES · U.S. SEC, Electronic Recordkeeping Requirements adopting release, October 12, 2022 · Advisers Act Rule 204-2(a)(7) · SEC recordkeeping enforcement orders, September 2022 onward · Regulation (EU) 2024/1689 and the European Commission's published implementation timeline.

B / C
III.

Six questions to ask any vendor

Each one is answered here with a record you can inspect.

Where does your record of the decision begin?

In the list of limit breaches. A limit breach is recorded before the order is placed, with the committed plan and the figure attached.

Can anything in the record be edited or deleted?

Not in the audit log or the acknowledgements. Both are append-only, and each entry carries the officer and the time. Plans and their limit checks can still be edited, and anyone with the database password can change any record. How long you keep records is your firm's policy.

What leaves our environment, exactly?

It runs fully locked down in your firm's own cloud account, set up by your own administrator. Nothing in it can send data out except to the Microsoft services it runs on, and we never hold your keys or have access to it. You get two records about the detail. The first is a list of every network connection DojiPad's server software can open. It is generated from the same settings the system enforces, so the list cannot drift from what actually runs. The second is a check of your own network logs, connection by connection, against that list.

How both records are produced →

Can the vendor see our trades?

No. It runs fully locked down in your firm's own cloud account, used by your firm alone and set up by your own administrator. Nothing in it can send data out except to the Microsoft services it runs on, and we never hold your keys or have access to it. Two records are reviewed live with your security team under NDA. One shows which roles can open which screens, and that the firm's screens and reports can't retrieve the trader's side. The other is the check of your own network logs.

The technical detail is on the technology page →

What happens when the system cannot measure something?

If DojiPad can't map an instrument, it says so rather than guessing. The daily sign-off row reads “not measured, so it is not a pass”. And when a limit in your firm's document cannot be encoded, the proposal arrives as not expressible instead of as a guessed number.

How is the AI's own output governed?

Each breach prediction is checked against the trader's next committed plan. Rating tiers are withheld when there are too few cases to judge. And every PDF carries an audit stamp that names what it covers.

IV.

The regulatory alignment memo

The full regulatory mapping, in a document your compliance team can file. You can have it before a briefing. It is delivered by email.

Resources · Regulatory memo

Request the regulatory memo

Your details

Give your work email, firm and function. We send the memo to that address.

VI.

What a security review under NDA covers

  • The network layout of the private deployment, shown live in your firm's cloud account.
  • What each part of the deployment can send out, and the evidence for each part.
  • The separation between the trader's side and the firm's side, shown from an officer's seat and a trader's seat.
  • Identity: how your Entra ID groups (your firm's staff directory) map to roles, and what each role can open.
  • The records: where the audit trail is kept, and how it is exported.

The two-page security brief covers the boundary, the evidence, identity, and how long records are kept (retention): read it as a page or download the PDF.

Due diligence

  • We complete operational due diligence questionnaires.
  • Security reviews run live with your security team, under NDA (what a review covers).
  • The deployment produces its own evidence: what is allowed to leave, and proof that the firm's screens and reports can't retrieve the trader's side.
  • Your auditors can inspect DojiPad where it runs: in your firm's own cloud account.
  • The list of findings from our own deployment rehearsal is available to your compliance team on request.

ARQNXS OÜ (Estonia), incorporation in progress.ARQNXS was founded in 2017 by Nigel van der Laan and is based in Amsterdam and Barcelona.

Company details on the About page →

What DojiPad doesn't do

  • It doesn't block, restrict or route orders. Ever.
  • We can't see your trades. Nothing in your deployment calls back to us.
  • It doesn't read your traders' screens, email, messaging apps or orders.

These three statements are quoted from the product's own screens.

Does not block, restrict, or route orders. No execution feed connected; silence here is not a clean bill. The trader's dialogue is never summarised, scored, or forwarded.

In plain terms: DojiPad never stops, limits, or sends an order. Until the feed of your executed trades is connected, an empty screen does not mean all is well. The trader's coaching conversation is never summarized, scored, or passed on.

What DojiPad doesn't do yet

Today DojiPad checks plans, not executed trades. It doesn't yet read market data or your executed trades (the execution feed). Both are on the roadmap, as one-way connections into DojiPad.

What that means today:

  • DojiPad sees the plans traders state. Your desk decides which decisions need a stated plan, for example every new position or anything above a set size. Until the execution feed is connected, your team checks coverage against its own order log.
  • Limits are checked on the plan as stated, using the plan's own price and your capital figures (NAV, firm book or desk book, as each limit specifies).
  • Comparing what was planned with what was executed starts when the execution feed is connected.
  • Each breach prediction is checked against the trader's next committed plan. Checking predictions against executed trades arrives with the feed.
  • The product says so on screen: “Session monitoring is not active — no execution feed is connected. Silence here is not a clean bill.”