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Control 1.22: Information Barriers for AI Agents

Control ID: 1.22 Pillar: Security Regulatory Reference: SEC Rules 10b-5, 14e-5, Regulation M; FINRA Rules 2241, 3110, 5270, 5280; OCC 2011-12 Last UI Verified: January 2026 Governance Levels: Baseline / Recommended / Regulated Last Verified: 2026-02-03

Objective

Implement information barriers (Chinese walls) to prevent AI agents from crossing compliance boundaries between business units, ensuring agents cannot access data across research-trading, investment banking-sales, or public-private side barriers.

Why This Matters for FSI

  • FINRA 3110: Enforces supervision and separation between research and trading functions
  • SEC Regulation SHO: Helps prevent trading on research information through segment barriers
  • FINRA 5280: Blocks research-trading communication to prevent trading ahead
  • OCC 2011-12: Supports AI data segregation requirements for model risk management

Control Description

This control establishes information barriers through:

  1. User Segments - Define segments based on Microsoft Entra ID attributes (Department = Research, Trading, IB, Sales)
  2. Barrier Policies - Configure policies that block communication between segments
  3. Agent Context Inheritance - Agents inherit barrier policies of the invoking user
  4. SharePoint Barrier Alignment - Knowledge sources respect barrier boundaries
  5. Wall-Crossing Workflow - Controlled exceptions with compliance approval and documentation
  6. Barrier Monitoring - Detect and alert on potential barrier violations

Channel Agent vs. Copilot Studio Agent IB Support

Information Barriers support varies by agent type in Teams:

Agent Type IB Supported Deployment Method Barrier Enforcement
M365 Copilot ✅ Yes Built-in User context inherits barriers
Copilot Studio agents in Teams ✅ Yes Teams app package User context inherits barriers
Channel Agent ❌ No Teams channel post No barrier inheritance

Channel Agent Limitation: Channel Agents posted to Teams channels do NOT inherit barrier policies from the channel or invoking users. This is a Microsoft platform limitation specific to the Channel Agent deployment model.

Copilot Studio agents ARE supported: Copilot Studio agents deployed to Teams via app packages DO respect Information Barriers when invoked by users in barrier-protected segments.

Compensating Controls for Channel Agents:

  • Zone 3 prohibition: Do not deploy Channel Agents in Teams channels where barrier-protected segments interact
  • Knowledge source isolation: Manually verify Channel Agent knowledge sources contain no cross-barrier content
  • Compensating controls: Use connector policies (Control 1.4) to restrict Channel Agent data access
  • User training: Ensure users understand Channel Agents operate outside IB enforcement scope

Testing Note: Before deploying any agent to Teams channels used by barrier-protected segments, test barrier enforcement by having a user from one segment invoke the agent and verify they cannot access content from the blocked segment.

Key Configuration Points

  • Create organization segments in Purview (IB-Research, IB-Trading, IB-InvestmentBanking, IB-Sales, IB-Compliance)
  • Configure Information Barrier policies blocking cross-segment access
  • Ensure all users are assigned to appropriate segments (users without segments bypass barriers)
  • Note: Information Barriers support up to 5,000 segments per tenant and users can be assigned to up to 10 segments simultaneously (multi-segment support)
  • Select the appropriate IB mode for your organization: Single Segment (legacy, one segment per user), Multi-Segment (up to 10 segments per user), or People Search (IB scoping for people directory search only)
  • Validate SharePoint site permissions align with barrier policies
  • Establish wall-crossing approval workflow (Compliance + Legal + Business Unit head)
  • Configure KQL monitoring for cross-barrier access attempts
  • Retain wall-crossing documentation for 6+ years

Zone-Specific Requirements

Zone Requirement Rationale
Zone 1 (Personal) Barriers inherited from user automatically User context provides enforcement
Zone 2 (Team) SharePoint sites validated for barrier compliance; weekly audit Team agents must stay within barrier walls
Zone 3 (Enterprise) Mandatory enforcement; knowledge source validation; real-time monitoring; formal wall-crossing Maximum protection for regulated functions

Roles & Responsibilities

Role Responsibility
Purview Compliance Admin Configure Information Barriers, define segments
Compliance Officer Approve wall-crossing requests, policy decisions
Entra Security Admin Monitor barrier enforcement, investigate violations
AI Governance Lead Validate agent knowledge sources for barrier compliance
Control Relationship
1.3 - SharePoint Governance SharePoint permissions must align with barriers
1.7 - Audit Logging Barrier events must be logged
1.18 - RBAC Access control aligned with barriers
2.8 - Segregation of Duties Organizational separation supports barriers

Implementation Playbooks

Step-by-Step Implementation

This control has detailed playbooks for implementation, automation, testing, and troubleshooting:

Verification Criteria

Confirm control effectiveness by verifying:

  1. Segments defined for all relevant business units in Purview
  2. Barrier policies show Active status between designated segments
  3. User in Research segment cannot access Trading content via agent
  4. Wall-crossing request routes to Compliance for approval
  5. Barrier audit logs capture all barrier-related decisions

Additional Resources

Updated: January 2026 | Version: v1.2 | UI Verification Status: Current