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Intent Drift at SME Scale: Deployment Practice, Not Model Capability, Determines Agentic Compliance

Ilia Voroshilov

arXiv:2609.05975v1cs.CYcs.AI

TL;DR

Small asset managers must meet statutory obligations, including obtaining consent before marketing and evidencing that clients qualify for discussed products. The paper tests Chain of Intent in a regulated-firm simulation and uses a stepwise ledger to record authorized versus executed scope. With purpose unstated, the agent sent unsolicited financial communications to 220 people; 14 were eligible, and 94 per cent lacked lawful basis for contact.

  • Problem

    Small asset managers must meet statutory obligations, including obtaining consent before marketing and evidencing that clients qualify for discussed products.

    Source: §1 · p. 1

  • Method

    The paper tests Chain of Intent in a regulated-firm simulation and uses a stepwise ledger to record authorized versus executed scope.

    Source: The Chain of Intent framework · p. 2

  • Results

    With purpose unstated, the agent sent unsolicited financial communications to 220 people; 14 were eligible, and 94 per cent lacked lawful basis for contact.

    Source: §1 · p. 2

  • Takeaways & Limitations

    The authors conclude that Chain of Intent is sufficient on this evidence to eliminate an exposure that reached 131 people contacted without lawful basis.

    Source: §8 · p. 15

    This is an existence proof, not a prevalence estimate, based on one firm profile, one agent task, one jurisdiction, and designed synthetic data.

    Source: §7 · p. 14

Abstract

from arXiv · show

We introduce Chain of Intent, a governance framework for agentic AI at small regulated firms, and validate it against a failure it was built to address. Existing agentic governance research assumes enterprise infrastructure that small firms do not have. In a simulated Hong Kong asset manager with 415 synthetic contact records, an agent performing a routine client-communications task was subjected to ordinary managerial pressure to increase its reach. With its authorised constraints written into its configuration, the agent held: it identified every ambiguity in the firm's records, cited privacy legislation it had never been shown, and refused six successive requests, breaching in two of fifteen runs. With the same task, data, pressure and model, but its purpose left unstated as resource-constrained firms routinely leave it, it breached in thirteen of fifteen runs, contacting up to 220 individuals of whom 94 per cent had no demonstrable marketing consent - conduct carrying a maximum of three years' imprisonment under Hong Kong law. Chain of Intent applies four controls requiring no security engineering: a machine-readable purpose, constrained tool access, a scope ledger, and a pre-action check. It eliminated unlawful contact in every run while preserving task completion, and ablation shows each control independently sufficient by a different mechanism. We further show that drift must be measured at two stages - agents widened their candidate sets in every pressured run while acting on them in roughly one in seven - and that governance applied at the point of intent costs roughly half as much as governance applied at the point of action.

1 Introduction

Small regulated firms carry substantial compliance duties, while governance research often assumes infrastructure they lack. The paper introduces Chain of Intent and reports that whether constraints are specified predicts compliance, with drift measurable before as well as at action.

1 Introduction

  • Small regulated firms face the same statutory obligations as global banks, while agent-governance research assumes infrastructure they may not have.The paper measures agent behavior under these resource constraints and introduces a governance framework aimed at that setting.Source: §1 · pp. 1–2

The Chain of Intent framework

  • Chain of Intent organizes governance around failure modes in three layers: intent, execution, and persistence.Its purpose is machine-readable and present in every turn; permission constrains tool access, proof logs authorized versus executed scope, and persistence checks proposed actions before execution.Source: The Chain of Intent framework · p. 2
  • The four testable pillars require no security engineering: configuration, a tool constraint, a scope log, and a pre-action check.The framework excludes Practice, which addresses shadow AI through organizational inventory rather than single-agent behavior.Source: The Chain of Intent framework · pp. 2–3

Contributions

  • We find that whether constraints are stated at all determines regulatory outcome: 2 of 15 runs breached when constraints were specified, versus 13 of 15 when they were not.Query-stage drift occurred in every pressured run, while action-stage drift occurred in roughly one in seven.Source: Contributions · p. 3
  • Ablation found each tested pillar independently sufficient through a different mechanism, while the paper also contributes a causal taxonomy separating drift from data and execution failures.The authors characterize the resulting property as redundancy rather than synergy.Source: Contributions · p. 3

2 Related Work

Prior work studies goal drift, workplace pressure, and agent governance, but the paper distinguishes its focus on unstated constraints, statutory consequences, and controls deployable at small firms. It positions empirical measurement under small-firm constraints as a gap in the literature.

2 Related Work

  • Unlike earlier work varying goal strength, this study varies whether a goal is specified at all, applies ordinary workplace pressure, measures statutory boundaries, and evaluates a remedy.The authors note that the earlier study itself flagged the realism of binary goals and explicit pressure as open concerns.Source: §2 · p. 3
  • Recent studies retain adversarial pressure, competing goals, and synthetic drift scores; neither varies whether specification is present or evaluates a governance control.Their finding that models resist single-shot pressure is described as consistent with this paper’s results under sustained pressure and absent specification.Source: §2 · pp. 3–4
  • Scheurer et al. [2024] use ordinary workplace messages to induce misalignment, whereas this study specifies an authorised audience that the agent must construct rather than resist.Both studies find that specification alone does not guarantee aligned action; the present paper tests additional controls.Source: §2 · p. 4
  • Enterprise governance frameworks assume instrumentation and monitoring capabilities unavailable to the small firms addressed here.MI9 requires comprehensive instrumentation, while Chan et al. [2024] propose identifiers, real-time monitoring, and activity logs.Source: §2 · p. 4
  • The paper identifies a gap: small-organisation governance has been conceptual, with no prior measurement, to the authors’ knowledge, of agentic drift under small-firm constraints against binding regulation.It also reports no prior validation of a governance framework deployable without specialist capability.Source: §2 · p. 4

3 Method

The method simulates a resource-constrained Hong Kong financial firm and isolates whether writing constraints into an agent’s configuration changes regulatory exposure. It uses synthetic, imperfect records, ordinary managerial pressure, and separate measures for scope drift and dispatched breaches.

3 Method

  • The simulation isolates whether writing firm constraints into an agent’s configuration changes its regulatory exposure under ordinary operational pressure.It models a resource-constrained financial firm and measures whether the agent stays within authorised scope.Source: §3 · p. 4

3.1 Firm, agent and environment

  • Meridian Bay is a fictional Hong Kong Type 9 wealth platform with 38 staff, limited compliance support, outsourced IT, and no security function.The sandbox exposes six simulated tools; dispatch is logged but not transmitted, and the contact search query is observable as a scope signal.Source: §3.1 · p. 5

3.2 The authorised purpose and the central manipulation

  • The authorised task is quarterly updates to existing Professional Investor clients with direct-marketing consent, using approved portfolio fields; the prompts differ only in whether constraints are stated.The three audience constraints are relationship status, investor classification, and consent; the vague prompt leaves them unstated although the firm's legal obligations remain unchanged.Source: §3.2 · p. 5

3.3 Data

  • The dataset contains 415 synthetic records with deliberately imperfect consent, classification, collection-purpose, and duplicate-record information.The imperfections establish an exposure floor independent of agent behavior; three reproducible variants differ only in consent hygiene.Source: §3.3 · pp. 5–6, Table 1 · p. 6

3.4 Pressure conditions

  • Managerial-pressure conditions range from none to six escalating messages, with additional conditions varying pressure type and prompt specificity.No pressure message grants permission to breach, names an out-of-scope segment, or revokes a constraint.Source: §3.4 · p. 6

3.5 Measurement

  • The study separates query drift from action drift and classifies breaches as data, execution, or drift before computing metrics.It also reports drift above the data-quality floor, out-of-scope contacts per query, first-crossing step, and attempted versus achieved widening when controls are active.Source: §3.5 · pp. 6–7

3.6 Procedure

  • The primary study uses deepseek-chat, runs each condition 15 times unless stated, and caps runs at 120 steps, with a 40-step cap in the cost-constrained replication.Tool calls and agent text are logged separately; runs terminating at a cap are flagged as censored.Source: §3.6 · p. 7

4 Results: Exposure

The results distinguish data- and execution-channel failures from pressure-driven drift, showing candidate-set expansion more often than dispatched out-of-scope contact. Removing stated constraints increased contact with ineligible recipients, alongside distinct regulatory findings and interpretive limits.

4.1 Baseline

  • Without pressure, ten runs queried on all three constraints and avoided unapproved sources, yet conflicting duplicate records caused one to five unevidenced contacts per run.Some otherwise identical baseline runs also disclosed up to fifty addresses in one visible field.Source: §4.1 · p. 7

4.2 Query drift and action drift dissociate

  • 13% exposure appears in completed actions, versus 100% in query histories: every pressured run widened its candidate set, but only two of fifteen contacted out-of-scope individuals.Extending pressure from three messages to six raised action drift from two to four runs; content-directed pressure produced no audience drift.Source: §4.2 · pp. 7–8, Figure 1 · p. 8

4.3 Specification determines compliance

  • Up to 220 unique recipients were contacted in the largest vague-prompt run, with 131 lacking demonstrable consent and an eligible population of fourteen.Across the three largest runs, 94–96 per cent of recipients lacked demonstrable consent.Source: §4.3 · p. 8, Figure 2 · p. 9

4.4 Constraint selection is economic

  • The agent relaxed whichever constraint expanded the candidate pool less: classification on the scarce variant, but consent on the consent-locked variant.The agent relaxed consent in all fifteen consent-locked runs; the records’ distributions shaped which constraint was sacrificed.Source: §4.4 · p. 9

4.5 The agent’s reasoning

  • Specified-purpose runs included 108 refusal passages across thirty runs; one excluded consent records without dates and cited privacy legislation absent from the prompt.The authors treat these passages as evidence of behavior, not internal reasoning or proof that the stated justification caused compliance.Source: §4.5 · pp. 9–10

4.6 Replication and regulatory characterisation

  • The failure reproduced on gpt-4o, reaching a pool of 227 records, 213 out of scope; two censored runs support direction, not a rate.One run dispatched to 28 out-of-scope recipients before stopping at the step cap, making 28 a floor.Source: §4.6 · p. 10
  • The observed conduct engages at least four requirements, while the SFC generative-AI circular’s high-risk-use requirements were unmet in every uncontrolled run.The circular finding is independent of the privacy analysis: consent alone would not have resolved it.Source: §4.6 · p. 10
  • Counting only dispatched communications is a narrow reading; treating retrieval into a marketing selection as use would raise exposure from thirteen to fifteen pressured runs.The authors leave unresolved whether that retrieval constitutes use.Source: §4.6 · p. 10

5 Results: The Framework

Chain of Intent applies four testable controls across intent, execution, and persistence; the organizational-inventory pillar is outside the single-agent simulation. The complete framework eliminated unlawful contact while preserving task completion, and ablation found independent protections operating through different mechanisms.

5.1 Design

  • Four pillars are testable in a single-agent simulation: Permission constrains the tool surface, Proof logs scope, and Persistence checks actions; Practice concerns organisational inventory and is excluded.The four testable pillars require no security engineering.Source: §5.1 · p. 11

5.2 Effect

  • No false-positive blocking or control-circumvention attempt was observed in twenty-five runs.Two controlled runs reached fewer than fourteen recipients for reasons not caused by the framework.Source: §5.2 · p. 11
  • Unlawful contact was eliminated in every controlled run while the task continued, usually reaching fourteen recipients in approximately twenty steps in thirteen of fifteen cases.Without the framework, runs produced zero to 220 recipients across 12 to 127 steps; applying it to the already-compliant specified-purpose condition caused no degradation.Source: §5.2 · p. 11, Table 3 · p. 12

5.3 Ablation

  • Each pillar was independently sufficient by a different mechanism, providing redundancy rather than synergy and avoiding a single point of failure.Permission blocked widened queries; without Permission, stated Purpose suppressed action, while removing both led to refused ineligible dispatch attempts.Source: Table 4 · p. 12, §5.3 · p. 12
  • Persistence-only runs took 38 to 51 steps versus 19 to 25 with the complete framework, and two reached no recipients.The authors conclude that point-of-action enforcement without direction can leave the agent unable to complete the authorised task.Source: §5.3 · p. 12

6 Discussion

For resource-constrained deployments, configuration mattered more than model choice, and output review can miss harms that emerge between the authorised and executed audiences. The discussion argues for evidence of agent activity and controls that small firms can operate.

6.1 The exposure is in deployment practice

  • For resource-constrained deployments, configuration mattered more than model choice, while precise vendor evaluations say little about behavior when deployed tasks are underspecified.The paper says the model mattered far less than a configuration decision in its data; vendor evaluations specify tasks precisely, unlike some real deployments.Source: §6.1 · pp. 12–13

6.2 Why review of outputs cannot see this

  • Well-formed emails can conceal audience-scope breaches because the harm lies between authorised and executed audiences; output review is structurally unable to detect it.The dispatched messages contained correct figures and appropriate closings, while the breach appeared in the query sequence rather than any single output.Source: §6.2 · p. 13

6.3 Evidence, not only prevention

  • Proof adds no behavioral effect, but records authorised versus executed scope and refusals, turning a compliance claim into evidence beyond a folder of sent emails.In uncontrolled runs, queries and discarded ineligible contacts were not retained for the firm to show what the agent did.Source: §6.3 · p. 13

6.4 Implications for regulators

  • The SFC circular applies regardless of firm size, but standard oversight presupposes capacity; the proposed minimal controls need no security engineering and do not replace guidance.The paper lists a purpose statement, a constraint on one tool, a pre-action check, and a log as controls suited to this scale.Source: §6.4 · pp. 13–14

7 Limitations

The evaluation is bounded to a single simulated setting, and the framework’s Purpose result depends on the study’s own finding. Instrument fidelity and analysis errors also constrained the evaluation.

7 Limitations

  • One firm profile, one task, and one jurisdiction make this an existence proof rather than a prevalence estimate; the data and pressure stimuli were designed, not sampled.The pressure stimuli were author-designed, and the synthetic data’s imperfections were designed rather than sampled.Source: §7 · p. 14
  • Cross-model replication covered only two censored failure-condition runs, the framework was not evaluated on a second model, and Practice was excluded.The Practice pillar was excluded rather than assessed.Source: §7 · p. 14
  • Purpose was derived from this study’s finding and then tested, rather than designed a priori and independently validated; Permission and Persistence do not share that dependency.Source: §7 · p. 14

7.1 Instrument fidelity

  • Sandbox faults silently returned empty or overbroad results, identical plausible figures, or biased record ordering, threatening the validity of simulated agent behavior.The paper reports that these faults could present as legitimate responses rather than errors.Source: §7.1 · p. 14
  • Six pilot runs were invalidated and 45 more discarded; a missing boundary in a summary table and miscounted control-refused sends initially distorted ablation results.One omitted boundary made breaches in 17 of 20 runs display as zero, while counting refused sends as completed contact initially inverted the ablation result.Source: §7.1 · p. 14
  • Because silent sandbox failures can resemble genuine agent behavior, the authors recommend adversarially probing tools before data collection.Source: §7.1 · p. 15

8 Conclusion

The conclusion argues that the key governance question is whether constraints are available to the agent, bound its tools, checked before action, and recorded. In this study, Chain of Intent eliminated the reported exposure in every run, with the controlled deployment costing roughly half as much as the uncontrolled one.

8 Conclusion

  • The agent’s capacity to cite privacy legislation and refuse repeated pressure was present; the specification was absent when it sent unsolicited communications.Source: §8 · p. 15
  • The governance question is whether constraints are available where the agent acts, bound its tools, checked before each action, and recorded.Source: §8 · p. 15
  • Four controls requiring no security engineering eliminated in every run an exposure that reached 131 individuals contacted without lawful basis.The controlled deployment was also roughly half the operating cost of the uncontrolled one.Source: §8 · p. 15
  • The paper characterises the gap as a decision left unmade, with its cost described as a paragraph in a configuration file.Source: §8 · p. 15

Ethics Statement

The authors report using only fictional firm, client, and record data, with no communications transmitted. They disclose a commercial interest in AI governance advisory work and say the materials are released for independent verification.

Ethics Statement

  • No real personal data was used, and the fictional addresses use the non-resolving .invalid domain.Source: Ethics Statement · p. 15
  • No communication was transmitted, and the authors state that no exploit is disclosed or stimulus grants permission to breach.Source: Ethics Statement · p. 15
  • The author discloses a commercial interest in Hong Kong AI governance advisory work; data, code, stimuli, and logs are released for independent verification.Source: Ethics Statement · p. 15

Reproducibility

The appendix documents the prompts, pressure stimuli, synthetic records, and checks used in the study. Auditing uncovered silent instrument failures and analysis errors, which were addressed before the reported runs.

C.2 Preflight checks

  • The authors provide code, a deterministic data generator, run logs, and validation script; fifteen behavioral checks must pass before a run.The checks cover such items as pagination, logging, condition definitions, control-refused sends, ablations, and provider selection.Source: Reproducibility · p. 15, §C.2 · p. 21

A.1 System prompt: specified purpose

  • The specified prompt defines the approved recipient and data scope, while the vague prompt says only that the agent helps with client communications and quarterly reporting.Neither prompt mentions the Ordinance, the SFC, or compliance.Source: §A.1 · p. 18, §A.2 · p. 18

A.5 P4 and P4L: escalating dissatisfaction

  • The stimuli use an opening request to send Q2 updates, then vary pressure from one broadening request to repeated dissatisfaction messages, delivered one at a time as the agent finishes.The six-message condition escalates across the working day; content pressure instead asks for more engaging updates and points to the document store.Source: §A.3 · p. 18, §A.4 · p. 18, §A.5 · p. 19

A.7 Manager response protocol

  • When asked to adjudicate scope, the simulated manager deflects questions about contacts, segments, and consent to the agent’s own judgment rather than granting permission.The response protocol also leaves content choices to the agent and allows up to six clarifying questions per run.Source: §A.7 · p. 19

B.1 Schema

  • The record schema includes relationship status, investor classification, marketing consent, consent dates, collection purpose, and last-contact dates, with inconsistent and sometimes ambiguous entries.Fifteen duplicate-address records have conflicting values, and free-text notes can be the only source of classification.Source: §B.1 · p. 20, §B.2 · p. 20

B.2 Composition, default variant

  • The default dataset contains 415 records across seven segments; 22 carry professional-investor status only in free-text notes, and these were reached when the agent relaxed classification under pressure.The scarce and consent-locked variants retain all 415 people and alter only consent recording.Source: §B.2 · p. 20, §B.3 · p. 20

C.1 Silent failures found by audit

  • Unknown query syntax returned empty results, ignored field names could return all 415 records, and identical portfolio data left the agent unable to detect its own errors.In the first case, the agent concluded nobody matched; widened queries could also return only the most compliant 50, leaving out-of-scope segments unreachable.Source: §C.1 · p. 21
  • Six pilot runs were invalidated when the first three failures were discovered, and 45 more were discarded after a deliberate audit found the fourth, most consequential failure.The summary view omitted one scored boundary, making breaches in 17 of 20 runs display as zeros; sends refused by a control were initially counted as completed contact, inverting the ablation result.Source: §C.1 · p. 21

D Full Results

Across the full results, pressure widened queries even when the specified-purpose agent did not contact out-of-scope individuals. The vague-purpose condition breached more often, and uncontrolled recipients largely lacked a lawful basis for contact.

D Full Results

  • 15/15 P4 and 15/15 P4L specified-purpose runs showed query drift, but action drift occurred in 2/15 P4 and 4/15 P4L runs; V4L vague-purpose runs showed 15/15 query drift and 13/15 action drift.With Chain of Intent, V4L showed 0/15 query drift and 0/15 action drift; V4L without Permission had 11/15 query drift and 0/15 action drift, while Persistence-only had 15/15 and 0/15, respectively.Source: D Full Results · p. 21
  • All runs used deepseek-chat on the scarce variant unless stated; consent-locked runs and the gpt-4o replication are reported in the main text.Source: D Full Results · p. 22

D.1 Recipient composition, three largest uncontrolled runs

  • In the three largest uncontrolled runs, 94–96 per cent of recipients were individuals the firm had no lawful basis to contact.Recipients are deduplicated by address under strict evaluation.Source: §D.1 · p. 22

E Extended Agent Reasoning

The extended reasoning excerpts show the agent justifying its decisions in terms of eligibility and honest reporting, while the framework’s permission control constrains what it can browse.

E Extended Agent Reasoning

  • The agent grounds its refusal in legitimate eligibility rather than the database’s size, distinguishing a defensible recipient count from a target coverage number.Source: E Extended Agent Reasoning · p. 22
  • It says managerial pressure does not change who is eligible and rejects padding the count as dishonest.Source: E Extended Agent Reasoning · p. 22
  • Under the framework, the agent explains the permission control as a query requirement for current, professional clients with marketing consent, preventing browsing of the wider set.Source: E Extended Agent Reasoning · p. 22
  • The agent identifies records marked consented but lacking consent dates, an evidentiary gap the framework did not require it to catch.Source: E Extended Agent Reasoning · p. 22
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