Solutions / External asset managers

One book, several rulebooks, one standard of evidence.

An external asset manager carries a book across custodians and borders, and answers to more than one supervisor for the same client. Luscent generates the evidence once, as the work happens, with the jurisdiction attached.

Luscent is a relationship intelligence platform for external asset managers: client Signal detection, MiFID II suitability evidence, and an exportable audit trail, across every custodian the book sits on.

Pilot
90 days, free
Seats
3 to 5
Data
EU only
Writes back
Nothing

What this book looks like from here.

01

The book sits on platforms you do not control.

Positions live in someone else's format on someone else's schedule. What you control is the relationship, and nobody reads it back.

02

Two supervisors, one client, two standards of proof.

Keeping one set of evidence and hoping it satisfies both frameworks is the common approach and the fragile one.

03

Small teams carry large books.

More clients per person than a bank, and no supervision layer to catch what gets missed.

95%
of wealth and asset managers have scaled generative AI to more than one use case; 27 percent report substantial business impact.
EY GenAI in Wealth and Asset Management Survey 2025 (100 firms)

What it looks like on the day.

Three pieces of the product, at the sizes they render at. Synthetic data throughout: every name and figure below is invented.

Signal feed2 today
Berger & Cie84%

Mandate scope questioned in two separate custodian threads.

Microsoft 365 · 5 messages · 9 days
Confirm mandate scope in writing
Routed to A. Novak
Lindeberg AG79%

A custodian statement query is still open.

Microsoft 365 · 1 message · 11 days
One prioritised feed across the whole book, which for a small team carrying a large one is the product.
Health Score
58down 14 in 45 days
Two unanswered questions about fees carried over from May.
A Health Score built from the relationship, so it does not break when a client changes custodian.
Evidence

Suitability recorded as the advice happens

MiFID II · rules fired
24.06.2026 11:27 · deterministic
The rule that fired is recorded with the result, so a cross-border file shows which framework produced which conclusion.

Two engines, and a rules core that never guesses.

The three things you just saw, and where each of them comes from.

A Signal carries a confidence because a model produced it. A compliance outcome carries the rule that fired and no confidence at all, because a regulatory result is not a guess. Tabular models are on the roadmap and are drawn that way.

What is connected, and what is not.

Microsoft 365 and Salesforce are live today. The two drawn dashed are on the roadmap and are not shipped. We would rather tell you that than let you assume otherwise. Nothing is written back into any of them: Luscent reads, and your systems of record stay exactly as they are.

Where this sits against the rules.

Fig. 2Relationship Intelligence for External Asset Managers | LuscentThe same communications feed two paths. A language model produces a Signal, which carries a numeric confidence and decides nothing. A deterministic rules engine, fed by MiFID II Article 25, GDPR Articles 28 and 32 and EU AI Act Article 50, produces a compliance record, which carries no confidence because a rule has none, and names the rule that fired. A named person decides on both paths.CommunicationsMail, calendar, meetingsYou already have themLanguage modelProbabilisticSignalCarries a confidence: 91Decides nothing.Puts it in front ofa person.Rules engineDeterministicCompliance recordCarries no confidenceA rule has noneto carry. The rulethat fired is named.MiFID II Art. 25 · GDPR Art. 28 and 32 · EU AI Act Art. 50
One body of communications, two paths out of it. The Signal carries a number because a model produced it. The record carries none, because a rule has none to carry, and it names the rule that fired.
MiFID II
Article 25
Suitability evidence generated as advice happens, with its source attached.
DeterministicTimestamped suitability record with the advice and its basis
Swiss FinSA and FinIA
Suitability and documentation
On the roadmap, not in the product today. A Swiss-booked mandate produces no FinSA or FinIA evidence.
RoadmapNothing yet
GDPR
Articles 28 and 32
Processed and stored in the EU, on Scaleway in Paris.
DeterministicProcessing record with lawful basis, retention and location

This describes what Luscent does, not what your firm is obliged to do. It is not legal or compliance advice. The platform generates evidence and surfaces Signals; decisions remain with the firm and its professionals at all times.

Who asks what.

Fig. 3Relationship Intelligence for External Asset Managers | LuscentFounder or CEO, Chief Operating Officer, Chief Information Officer, Head of Compliance, Relationship manager. Each holds a different concern and the deal advances only when the last of them is satisfied.Founder or CEOTime to valueChief OperatingOfficerCustodian changesChief InformationOfficerIntegration burdenHead of ComplianceWhich regimeRelationship managerDaily changeTHE DEAL ADVANCES WHEN THE LAST OF THESE IS SATISFIED, NOT THE FIRSTEach answered below
The seats that have to be satisfied, and the concern each one carries. Every question below is the first thing that seat asks.
Founder or CEO#leadership
How long before this is worth anything?
The pilot runs ninety days on synthetic data first, with success metrics agreed before day one. A relationship representation accumulates, so month six is worth more than month one and we say so rather than promising a fast win.
Chief Operating Officer#operations
What happens when a client moves custodian?
The understanding survives the move. A relationship representation is built from your own communications rather than from the platform holding the assets, so the positions change and what you know about the client does not.
Chief Information Officer#technology
What is the integration burden?
Microsoft 365 and Salesforce, read-only, through their own consent flows. Nothing is written back and nothing is migrated.
Head of Compliance#compliance
Which regime does the evidence answer to?
MiFID II, out of a deterministic rules core. FinSA and FinIA are on the roadmap, not in the product today, so a Swiss-booked mandate produces no Swiss evidence yet. A compliance outcome comes from the rules engine and never from a model.
Relationship manager#adviser
What do I have to do differently?
Read a list that is already in priority order. The evidence is produced from the work, not in addition to it.

Where this gets it wrong.

Every firm evaluating this has been shown a confident wrong answer by something before. So the limits are on the page rather than in the room, and each one names the control that catches it.

Fig. 4Relationship Intelligence for External Asset Managers | LuscentLuscent reads mail, calendar, meetings and CRM records. Telephone calls, conversations in person, personal channels and anything on a system it is not connected to are outside what it can see. Deterministic outcomes are exact and carry no confidence; probabilistic Signals carry a number; anything outside the boundary carries nothing because it is not there.WHAT IT READSMailCalendarMeetingsCRM recordsINVISIBLE TO ITTelephone callsCorridor conversationsPersonal channelsAnything not connectedDeterministic outcomes are exact and carry no confidence. Probabilistic Signals carry a number.Anything in the right-hand box carries nothing at all, because it never reached the system.
The edge of what the system knows. A relationship conducted outside the left-hand box does not appear in it at all, and no confidence number is attached to something that never arrived.
Confidence is a number, not a feeling.
Every probabilistic Signal carries a numeric confidence on its face. Deterministic outcomes carry none, because they have none to state: the same input produces the same result every time.
It reads what it is connected to, and nothing else.
A relationship conducted by telephone, in person, or on a channel Luscent does not read is invisible to it. The systems drawing above is the whole of what it can see.
It surfaces, it does not decide.
No Signal approves advice and no score authorises an action. Every consequential decision is taken by a named person, and the record says who.
It will be wrong, and the pilot counts it.
False positives are reviewed weekly with your compliance function during the pilot, and the rate is one of the success metrics agreed before day one rather than something discovered at the end.
A thin month is a thin month.
The representation of a relationship accumulates from your own communications. Month six is worth considerably more than month one, and no amount of capital shortens that for anyone.

What your outsourcing officer needs.

Whether a deployment is a critical or important function is your firm's classification to make, and your outsourcing officer owns it. What we can do is put the facts that classification turns on in one place, before you have to ask for them.

Fig. 5Relationship Intelligence for External Asset Managers | LuscentLuscent writes nothing into your systems, takes no decision and produces no client-facing output. Those three facts hold today. Whether a deployment is a critical or important function remains your firm's classification to make, and your outsourcing officer owns it.01Does it write into yoursystems?No02Does it take a decision?No03Does it produceclient-facing output?NoYour firmclassifies.We publish the facts.Your officer owns it.All three answers hold today and are checkable in the table below and in the Trust Center.
The three questions an outsourcing review opens with, and the answers that hold today. The fourth box is not an answer on purpose: the classification is the firm's, and a vendor drawing it as settled would be overreaching.
Written back into your systems
Nothing
Fact
Decisions taken by the system
None. A named person decides.
Fact
Output shown to your clients
None. Luscent is used by your staff.
Fact
Client data location
European Union only. Scaleway, Paris.
Fact
Sub-processors with access to client data
One. The full list is published.
Fact
Training on client data
None.
Fact
Security certification held
None. Controls aligned to ISO/IEC 27001:2022; certification planned 2027.
Fact
Audit and inspection rights
Your firm, its statutory auditor and its competent authority.
Position
Transition assistance on exit
Twelve months.
Position
Material sub-contracting
Prior written approval.
Position
Register of Information data sheet
Provided on request, in the fields you have to file.
Position

Fact means true today and checkable, here or in the Trust Center. Position means the stance Luscent takes into a negotiation; it binds nobody until it is in a signed agreement. The clause set behind the second group is Article 30 of Regulation (EU) 2022/2554.

Read the full Trust Center

Whether this is a fit.

Built for
Managers running Microsoft 365 in the Swiss and Luxembourg corridor
Books held across more than one custodian
Firms answering to more than one supervisor for the same client
Not built for
Firms looking for custodian aggregation or performance reporting
Firms wanting the system to place or approve a trade
Firms whose client contact happens by phone and stays there

The pilot is ninety days, free, with three to five relationship managers, starting on synthetic data. Success metrics are agreed before day one, so at the end there is something to judge rather than an impression.

Solutions / External asset managers

One book, several rulebooks, one standard of evidence.

An external asset manager carries a book across custodians and borders, and answers to more than one supervisor for the same client. Luscent generates the evidence once, as the work happens, with the jurisdiction attached.

Luscent is a relationship intelligence platform for external asset managers: client Signal detection, MiFID II suitability evidence, and an exportable audit trail, across every custodian the book sits on.

Pilot
90 days, free
Seats
3 to 5
Data
EU only
Writes back
Nothing

What this book looks like from here.

01

The book sits on platforms you do not control.

Positions live in someone else's format on someone else's schedule. What you control is the relationship, and nobody reads it back.

02

Two supervisors, one client, two standards of proof.

Keeping one set of evidence and hoping it satisfies both frameworks is the common approach and the fragile one.

03

Small teams carry large books.

More clients per person than a bank, and no supervision layer to catch what gets missed.

95%
of wealth and asset managers have scaled generative AI to more than one use case; 27 percent report substantial business impact.
EY GenAI in Wealth and Asset Management Survey 2025 (100 firms)

What it looks like on the day.

Three pieces of the product, at the sizes they render at. Synthetic data throughout: every name and figure below is invented.

Signal feed2 today
Berger & Cie84%

Mandate scope questioned in two separate custodian threads.

Microsoft 365 · 5 messages · 9 days
Confirm mandate scope in writing
Routed to A. Novak
Lindeberg AG79%

A custodian statement query is still open.

Microsoft 365 · 1 message · 11 days
One prioritised feed across the whole book, which for a small team carrying a large one is the product.
Health Score
58down 14 in 45 days
Two unanswered questions about fees carried over from May.
A Health Score built from the relationship, so it does not break when a client changes custodian.
Evidence

Suitability recorded as the advice happens

MiFID II · rules fired
24.06.2026 11:27 · deterministic
The rule that fired is recorded with the result, so a cross-border file shows which framework produced which conclusion.

Two engines, and a rules core that never guesses.

The three things you just saw, and where each of them comes from.

A Signal carries a confidence because a model produced it. A compliance outcome carries the rule that fired and no confidence at all, because a regulatory result is not a guess. Tabular models are on the roadmap and are drawn that way.

What is connected, and what is not.

Microsoft 365 and Salesforce are live today. The two drawn dashed are on the roadmap and are not shipped. We would rather tell you that than let you assume otherwise. Nothing is written back into any of them: Luscent reads, and your systems of record stay exactly as they are.

Where this sits against the rules.

Fig. 2Relationship Intelligence for External Asset Managers | LuscentThe same communications feed two paths. A language model produces a Signal, which carries a numeric confidence and decides nothing. A deterministic rules engine, fed by MiFID II Article 25, GDPR Articles 28 and 32 and EU AI Act Article 50, produces a compliance record, which carries no confidence because a rule has none, and names the rule that fired. A named person decides on both paths.CommunicationsMail, calendar, meetingsYou already have themLanguage modelProbabilisticSignalCarries a confidence: 91Decides nothing.Puts it in front ofa person.Rules engineDeterministicCompliance recordCarries no confidenceA rule has noneto carry. The rulethat fired is named.MiFID II Art. 25 · GDPR Art. 28 and 32 · EU AI Act Art. 50
One body of communications, two paths out of it. The Signal carries a number because a model produced it. The record carries none, because a rule has none to carry, and it names the rule that fired.
MiFID II
Article 25
Suitability evidence generated as advice happens, with its source attached.
DeterministicTimestamped suitability record with the advice and its basis
Swiss FinSA and FinIA
Suitability and documentation
On the roadmap, not in the product today. A Swiss-booked mandate produces no FinSA or FinIA evidence.
RoadmapNothing yet
GDPR
Articles 28 and 32
Processed and stored in the EU, on Scaleway in Paris.
DeterministicProcessing record with lawful basis, retention and location

This describes what Luscent does, not what your firm is obliged to do. It is not legal or compliance advice. The platform generates evidence and surfaces Signals; decisions remain with the firm and its professionals at all times.

Who asks what.

Fig. 3Relationship Intelligence for External Asset Managers | LuscentFounder or CEO, Chief Operating Officer, Chief Information Officer, Head of Compliance, Relationship manager. Each holds a different concern and the deal advances only when the last of them is satisfied.Founder or CEOTime to valueChief OperatingOfficerCustodian changesChief InformationOfficerIntegration burdenHead of ComplianceWhich regimeRelationship managerDaily changeTHE DEAL ADVANCES WHEN THE LAST OF THESE IS SATISFIED, NOT THE FIRSTEach answered below
The seats that have to be satisfied, and the concern each one carries. Every question below is the first thing that seat asks.
Founder or CEO#leadership
How long before this is worth anything?
The pilot runs ninety days on synthetic data first, with success metrics agreed before day one. A relationship representation accumulates, so month six is worth more than month one and we say so rather than promising a fast win.
Chief Operating Officer#operations
What happens when a client moves custodian?
The understanding survives the move. A relationship representation is built from your own communications rather than from the platform holding the assets, so the positions change and what you know about the client does not.
Chief Information Officer#technology
What is the integration burden?
Microsoft 365 and Salesforce, read-only, through their own consent flows. Nothing is written back and nothing is migrated.
Head of Compliance#compliance
Which regime does the evidence answer to?
MiFID II, out of a deterministic rules core. FinSA and FinIA are on the roadmap, not in the product today, so a Swiss-booked mandate produces no Swiss evidence yet. A compliance outcome comes from the rules engine and never from a model.
Relationship manager#adviser
What do I have to do differently?
Read a list that is already in priority order. The evidence is produced from the work, not in addition to it.

Where this gets it wrong.

Every firm evaluating this has been shown a confident wrong answer by something before. So the limits are on the page rather than in the room, and each one names the control that catches it.

Fig. 4Relationship Intelligence for External Asset Managers | LuscentLuscent reads mail, calendar, meetings and CRM records. Telephone calls, conversations in person, personal channels and anything on a system it is not connected to are outside what it can see. Deterministic outcomes are exact and carry no confidence; probabilistic Signals carry a number; anything outside the boundary carries nothing because it is not there.WHAT IT READSMailCalendarMeetingsCRM recordsINVISIBLE TO ITTelephone callsCorridor conversationsPersonal channelsAnything not connectedDeterministic outcomes are exact and carry no confidence. Probabilistic Signals carry a number.Anything in the right-hand box carries nothing at all, because it never reached the system.
The edge of what the system knows. A relationship conducted outside the left-hand box does not appear in it at all, and no confidence number is attached to something that never arrived.
Confidence is a number, not a feeling.
Every probabilistic Signal carries a numeric confidence on its face. Deterministic outcomes carry none, because they have none to state: the same input produces the same result every time.
It reads what it is connected to, and nothing else.
A relationship conducted by telephone, in person, or on a channel Luscent does not read is invisible to it. The systems drawing above is the whole of what it can see.
It surfaces, it does not decide.
No Signal approves advice and no score authorises an action. Every consequential decision is taken by a named person, and the record says who.
It will be wrong, and the pilot counts it.
False positives are reviewed weekly with your compliance function during the pilot, and the rate is one of the success metrics agreed before day one rather than something discovered at the end.
A thin month is a thin month.
The representation of a relationship accumulates from your own communications. Month six is worth considerably more than month one, and no amount of capital shortens that for anyone.

What your outsourcing officer needs.

Whether a deployment is a critical or important function is your firm's classification to make, and your outsourcing officer owns it. What we can do is put the facts that classification turns on in one place, before you have to ask for them.

Fig. 5Relationship Intelligence for External Asset Managers | LuscentLuscent writes nothing into your systems, takes no decision and produces no client-facing output. Those three facts hold today. Whether a deployment is a critical or important function remains your firm's classification to make, and your outsourcing officer owns it.01Does it write into yoursystems?No02Does it take a decision?No03Does it produceclient-facing output?NoYour firmclassifies.We publish the facts.Your officer owns it.All three answers hold today and are checkable in the table below and in the Trust Center.
The three questions an outsourcing review opens with, and the answers that hold today. The fourth box is not an answer on purpose: the classification is the firm's, and a vendor drawing it as settled would be overreaching.
Written back into your systems
Nothing
Fact
Decisions taken by the system
None. A named person decides.
Fact
Output shown to your clients
None. Luscent is used by your staff.
Fact
Client data location
European Union only. Scaleway, Paris.
Fact
Sub-processors with access to client data
One. The full list is published.
Fact
Training on client data
None.
Fact
Security certification held
None. Controls aligned to ISO/IEC 27001:2022; certification planned 2027.
Fact
Audit and inspection rights
Your firm, its statutory auditor and its competent authority.
Position
Transition assistance on exit
Twelve months.
Position
Material sub-contracting
Prior written approval.
Position
Register of Information data sheet
Provided on request, in the fields you have to file.
Position

Fact means true today and checkable, here or in the Trust Center. Position means the stance Luscent takes into a negotiation; it binds nobody until it is in a signed agreement. The clause set behind the second group is Article 30 of Regulation (EU) 2022/2554.

Read the full Trust Center

Whether this is a fit.

Built for
Managers running Microsoft 365 in the Swiss and Luxembourg corridor
Books held across more than one custodian
Firms answering to more than one supervisor for the same client
Not built for
Firms looking for custodian aggregation or performance reporting
Firms wanting the system to place or approve a trade
Firms whose client contact happens by phone and stays there

The pilot is ninety days, free, with three to five relationship managers, starting on synthetic data. Success metrics are agreed before day one, so at the end there is something to judge rather than an impression.