Layer 4: Trust Ledgers

How do I comply with SOX for AI agent financial operations?

Sarbanes-Oxley (SOX) requires that financial reporting systems maintain internal controls, audit trails, and change management processes — and AI agents processing financial data, generating reports, or executing transactions must satisfy these same requirements.

SOX compliance requirements for AI agents:

  • Section 302 (CEO/CFO certification): Executives must certify that internal controls over financial reporting are effective — including controls over AI agents that touch financial data
  • Section 404 (Internal controls assessment): Annual assessment of internal controls must include AI agent governance as a control point
  • Audit trail requirements: Every financial transaction must have a complete, tamper-proof audit trail — including transactions initiated or processed by AI agents
  • Segregation of duties: The same agent shouldn't both initiate and approve financial transactions — but most agent frameworks don't enforce this
  • Change management: Policy changes affecting financial processing must be documented, reviewed, and approved

Exogram provides SOX-compliant AI agent governance: Gate 4 (Billing Cap) prevents unauthorized high-value transactions. The Trust Ledger provides tamper-proof audit trails with SHA-256 state hashing. Namespace isolation enforces segregation of duties. Version-controlled policies satisfy change management requirements.

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