Built for MiFID II wealth managers

Your book, understood.

Luscent reads the communications your firm already has, shows every relationship manager the next right conversation, and generates the suitability evidence as the work happens.

Join the pilot programme See how it works

Luscent · demo environmentSynthetic clients

Clients127 relationships · the seven largest

01Von Liechtenstein-Belmonte74down 2 in 90 days87.400.000

02Klein Family Office76down 5, suitability expired42.000.000

03Ottersbach Trust68down 3, SLA breached36.900.000

04Lehnert Stiftung78up 1 in 90 days31.200.000

05Constance Delvaux72up 2 in 90 days22.150.000

06Kessler Privat62down 4 in 90 days19.870.000

07von Habermann55down 8, suitability expired18.450.000

Synthetic clients, EU names · select a rowHealth Score 0 to 100, rebuilt daily

92% · Comms to Compliance09:12

Klein Family Office · liquidity event

“the proceeds, roughly 9.200.000 EUR, will land next month”

Mail · Charlotte Klein

[01] The scoreFig. 1

It starts before the conversation: one number per relationship, and you can open it.

Every relationship carries a Health Score from 0 to 100, rebuilt daily from the communications your firm already produces. Low means attention, not risk. It is the noun the three use cases below are built from.

Health Score · Klein Family Office · May to July 2026Cooling

76/ 100▼ 5 · suitability review expired

827873107.05 · Mail · Opened the exchange220.05 · Call note · Objectives and horizon restated305.06 · Mail · Liquidity need stated by the client

Synthetic client, the same Klein Family Office and 42.000.000 EUR used across this site.

Open the number

Every move opens onto the messages it was drawn from.

1Opened the exchange07.05.2026 · Mail
2Objectives and horizon restated20.05.2026 · Call note
3Liquidity need stated by the client05.06.2026 · Mail

The expired suitability review is carried on the record as a date, beside the score rather than inside it.

Rebuilt daily

From mail, calendar and meetings the firm already produces. Nothing new to type.

Low means attention

Not risk, and not a verdict on the relationship manager. A number that asks for a conversation.

Opened, not trusted

The score is only worth having because it resolves to the exchanges behind it.

[02] Where it landsProduct version 1.4

A relationship manager's day, in six surfaces.

In the order they come up. The day starts on the Dashboard, a Client's email becomes a Signal, the Signal opens the Client and turns into a Task, and the afternoon prepares the reviews and the family meeting.

08:30 · Start of the day

Dashboard

DailyLive

The prioritised feed. What needs attention today, in order.

92%Klein Family Office · liquidity event09:12

RuleMarchetti Holding · 1 of 3 trades blocked09:31

84%Iris Hoffmann · cooling over 90 days10:40

09:12 · A Client writes

Signals

Live

Book-wide inventory, searchable by type, urgency and date.

88%Competitor namedChurn

81%Inheritance in progressRevenue

09:14 · Open the Client

Client Detail

Live

Seven tabs: Monitor, Detect, Execute, Connect, Allocate, Compliance, Documents.

MonitorDetectExecuteConnectAllocateComplianceDocuments

Suitability evidence filed · EV-2026-0614

09:20 · Turn it into work

Tasks

Live

What a Signal turned into, and who owns it.

Call Iris before the moved review

Confirm the Klein liquidity reading

11:00 · Plan the reviews

Clients

Live

The book, in three views, filtered however the desk works.

74Von Liechtenstein-Belmonte

76Klein Family Office

68Ottersbach Trust

14:00 · Before the family meeting

Wealth Map

In build

The household on one map: people, holdings, trusts and liabilities, each with its open Signals and the rules that bind it.

Klein household

8 entities · 7 open Signals

Regime divergence on household action · CriticalPROP-0113 spans both booking sleeves: MiFID II passes, CVM Res. 30 blocks the product class. Most restrictive wins: blocked, with a path to comply.

Fictional Klein household · as designedHover to trace ownership · select to openTap an entity to open it

[03] One record, in fullFig. 2

It does not end when the conversation does: the record itself, not a description of it.

One suitability record from the demo environment, read in three steps: what was advised, why it was suitable, and who signed.

EV-2026-0614 · suitability recordSynthetic

Klein Family OfficeLuxembourg · RM Anne Keller · portfolio review

Verdict: Suitable
Rule: MIFID2-SUIT-25
Confidence: Certain · a rule, not a model
Advice: 25.06.2026 · 14:20

What was advisedIn the relationship manager's words
Reduce the European small-cap sleeve from 12% to 6% and hold the proceeds in the existing money-market line until the September review.
The liquidity need stated on 05.06.2026 falls inside the horizon of the sleeve being reduced, and the objective restated on 20.05.2026 is capital preservation. Written by Anne Keller at the point of advice.
Why it was suitableMiFID II asks for five things. Each one carries a date.
Knowledge and experienceElective professional clientReviewed 04.02.2026
Financial situation42.000.000 EUR under advice, 3.000.000 EUR liquidity needStated 05.06.2026
Objectives and horizonCapital preservation over five yearsRestated 20.05.2026
Risk toleranceAssessment on file, unchanged04.02.2026
Capacity for lossAssessment on file, unchanged04.02.2026
Who signed, and whenWritten at the point of advice, not reconstructed later
Signed by Anne Keller, RM25.06.2026, 14:52 CEST32 minutes after the adviceIn the Audit Trail

Synthetic client and dates. The shape of the record is the claim, not the numbers inside it.

[10] Provenance

A rule identifier is a claim. This is what stands behind it.

The record is synthetic. The citations are not, and each one links to the published text rather than to a Luscent page about it.

LimbWhat MIFID2-SUIT-25 requiresOn this record

Knowledge and experienceAn assessment on file, and a client categorisation that has been reviewedPresent. Reviewed 04.02.2026.

Financial situationAssets under advice, and any liquidity need the client has statedPresent. Need stated 05.06.2026.

Objectives and horizonObjectives recorded, dated no later than the advice they supportPresent. Restated 20.05.2026.

Risk toleranceAn assessment on filePresent. 04.02.2026.

Capacity for lossAn assessment on file, held apart from risk tolerance rather than folded into itPresent. 04.02.2026.

Why it was suitableA reason written at the point of advice, attributed to a named personWritten by Anne Keller, 25.06.2026.

MiFID IIDirective 2014/65/EU, Article 25(2)eur-lex.europa.eu ↗MiFID II Delegated RegulationRegulation (EU) 2017/565, Articles 54 and 55eur-lex.europa.eu ↗ESMA guidelinesESMA35-43-3172, applying from 3 October 2023esma.europa.eu ↗

[04] On fileAfter the conversation

Everything on file after one conversation.

What exists once a Client has written and the Relationship Manager has decided. Each line says whether it is live today or in build.

A Signal, with the message it came fromLive
Suitability evidence, linked to its sourceLive
The MiFID II rule that applies, checked as a fixed ruleLive
Advice held until the Relationship Manager confirmsLive
A Task with an owner and a due dateLive
The Health Score updated, with the reasonLive
Relationship drift flagged before the reviewLive
Products matched to the Client’s identified needsLive
An Audit Trail entry: who read, who decided, whenLive
Your CRM stays the record: read, not written toLive
A supervision view for the compliance functionIn build
See it on a scenario from your firm

[05] GovernanceThe firm's side

Across the book: the firm's side of the same record.

Four surfaces for the compliance function and the Head of Private Banking. They read the record the relationship managers write, and none of them scores a relationship manager.

Audit Trail

Live

Who decided what, when and on which evidence, for every Client file. Written by the work itself, read by compliance.

Suitability evidence filed · EV-2026-0614Anne Keller · RM09:41

Rule fired · MiFID II Art. 25Deterministic09:40

Signal raised · Klein Family OfficeLiquidity event09:12

Override reason recorded · Marchetti HoldingAnne Keller · RM08:55

Supervision

In build

Client files and firm obligations in one view for the compliance function. It supervises files, never the relationship manager.

Klein Family OfficeSuitability review expiredOpen

Oliveira WealthTwo rulebooks disagreeOpen

Marchetti Holding1 of 3 trades blockedReviewed

By Client file and obligation. Never by relationship manager.

Directives

In build

A firm instruction to its relationship managers, scoped to the Clients it applies to, with who has acknowledged it.

D-2026-Q4-014 · Review offshore structured productsIssued by the Head of Private Banking

6 Clients in scope · 4 acknowledged

Claims

In build

House views and research claims taken from source documents, each with its confidence and the page it came from. Directives are written from them.

Underweight long duration into year endHouse view · 02.10.2026 · p. 14High

Private credit spreads to widenResearch note · 21.09.2026 · p. 3Medium

[06] Use casesRetention · growth · evidence

Three things the book saysbefore the report does.

Retention, growth and evidence, each standing on the Health Score. Every Signal is a recommendation; the relationship manager decides.

01Retention

The client who is leaving tells you first.

A departure is a sequence, not an event. The sequence is in the mailbox for months before it is in the AUM report, and it is legible: replies get shorter, the client starts opening the exchanges, a competitor gets named, a review gets declined twice.

Competitor DriftSentiment SpiralService Failure Loop

Luscent surfaces the sequence while it is still a sequence. What the relationship manager does about it is theirs.

The Relationship Drift use case →

02Growth

The money is already in the conversation.

Liquidity events, successions, an inheritance, a business sale, a tax question that only makes sense if something is about to happen. Clients say these things in passing, to someone who is reading for something else, and they do not come back.

New Money FlowHigh IntentPortfolio Focus

Ranked by what it is worth and how sure the system is, so a book of 127 relationships produces a list of three.

See it on the Dashboard →

03Evidence

The file writes itself, while the advice happens.

Suitability files get assembled afterwards, from memory, unevenly across a population of relationship managers. The reconstruction is the risk: it is slow, it is uneven, and at an inspection it is the thing that is hardest to defend.

Deterministic rulesNo model discretionAuto-resolves on fix

Compliance outcomes come from rules, never from a probability, and the rule that fired is written to the record.

The Comms to Compliance use case →

Six Signals, specified.

What each one looks for, what it reads and what it hands the relationship manager. Model Signals carry a probability; rule-based ones are certain or silent.

RetentionModel

Relationship Drift

Looks forReplies getting shorter and slower over weeks, reviews moved.

ReadsMail, calendar

Hands the RMA Task to call before the next review

71%Von Liechtenstein-Belmonte · replies getting shorter

RetentionModel

Competitor Drift

Looks forAnother firm named or compared in a conversation.

ReadsMail, Teams meetings

Hands the RMA Task to review the mandate terms with the Client

79%Kessler Privat · competitor named

GrowthModel

New Money Flow

Looks forMoney about to arrive: a sale, an allocation, an inheritance.

ReadsMail, call notes

Hands the RMA Task to prepare the proposal

84%Lehnert Stiftung · further allocation

GrowthModel

High Intent

Looks forA question that only makes sense before a decision.

ReadsMail, Teams meetings

Hands the RMA Task to book the conversation

77%Constance Delvaux · succession question

EvidenceModel

Comms to Compliance

Looks forA change in the Client's situation the suitability file must reflect.

ReadsMail, then the rules engine

Hands the RMA reading to confirm; advice waits until it is confirmed

92%Klein Family Office · liquidity event

EvidenceRule

Suitability

Looks forA suitability assessment past the firm's limit.

ReadsThe Client record

Hands the RMNew advice held until the assessment is renewed

Certainvon Habermann · assessment expired

Synthetic examples from the book above, in the demo environment.

[07] How it worksThe spine

Under the hood: seven stages, in one order.

Every Signal passes through all seven, left to right. Inference is the only stage a model touches, and the only one drawn as a model.

What Luscent reads, and what it hands back. The seven stages below are the same path, in order.

01Consent

Lawful basis recorded before anything is read

02Scope

Only what the firm connects and chooses to share

03Infer

EU-hosted inference, EU providers only

04Rules

Deterministic. No model discretion

05Explain

Evidence and rule attached to the output

06Decide

The relationship manager, always

07Audit

Every decision written to the Audit Trail

Inference is the only stage a model touches. Every other stage is deterministic or a person.

[08] What it will not doFour constraints

Four things it is built not to do.

Every firm evaluating this has been shown a confident wrong answer by something before. The controls behind these are set out in the Trust Center.

01 · Built not to

It does not send your clients' words to a US model.

Inference is hosted in the EU by EU providers only. No OpenAI, Anthropic or Google API sits in the path of client data.

EU serving boundaryEU providers onlyNo fine-tuning

02 · Built not to

It does not start on your real clients.

The pilot runs on synthetic data first. Real correspondence enters once the firm has seen what the system does with the invented kind.

Synthetic first90 days3 to 5 seats

03 · Built not to

It does not act on its own.

Every Signal is a recommendation. The relationship manager decides, and the decision is recorded against the client with the person who took it.

SignalRMDecision recorded

04 · Built not to

It does not ask you to take its word.

Every Signal carries the rule that gated it, the messages it was drawn from, and the model and version that read them.

Rule citedSource messagesModel and version

[09] What it coversProduct regulation only

What the rules core actually produces.

DORA and NIS2 describe how Luscent operates as your supplier rather than what the product produces, so they sit in the Trust Center instead.

RegulationReferenceStatusWhat Luscent produces

MiFID IIArticle 25LiveSuitability evidence written at the point of advice

GDPRArticles 28 and 32LiveLawful basis recorded before anything is read

EU AI ActArticle 50LiveModel outputs labelled as AI, a named person decides

CVM and ANBIMARes. 30, 178, 35, 19, 50LiveBrazilian resolutions run in the same rules engine

FinSA and FinIANot shippedRoadmapSwiss coverage is on the roadmap, not in the product today

LGPDData handlingAcknowledgedRecorded in the way Brazilian client data is handled

UK Consumer DutyNot shippedRoadmapOn the roadmap and not in the product. We would rather say so

WpHG, WpDVerOV and MaCompNot shippedRoadmapGerman conduct rules for banks and investment firms, not in the product today

FinVermV (§34f GewO)Not shippedRoadmapGerman rules for independent financial investment brokers, not in the product today

This describes what Luscent does, not what your firm is obliged to do. It is not legal or compliance advice.

[10] Next stepThe pilot programme

See it on a scenario from your firm.

Bring an anonymised client exchange. In twenty minutes you see the Signal it raises, the Task it suggests and the record it leaves, in the demo environment.

Join the pilot programme Read the Trust Center

90 days: One pilot, a fixed scope
Free: No licence fee during the pilot
3 to 5: Relationship managers
Synthetic first: Your scenario, anonymised, before any live data

Compared with what you have today

Luscent vs your CRMThe CRM records. Luscent reads what it records.Luscent vs building in-houseWhat a bank team would have to build, and keep current.Luscent vs communications surveillanceMisconduct alerts for compliance, or Signals for the relationship.Luscent vs CopilotA general assistant, or a record a supervisor can rely on.