AI Washing: What the SEC's First Two Cases Mean for How You Describe Your Own AI Use

Black Lily Blog, by William Dorman, Founder of Black Lily. Compliance · Sep 2026.

In March 2024 the SEC charged two advisers for saying they used AI in ways they did not. The lesson is not to stay quiet about AI. It is that the description has to match the deployment, which is easier when you can point at the machine.

How Black Lily is different: every engagement is scoped, sized, installed, trained, and maintained directly by the founder, with no account managers and no subcontractors. We install open-weight models we did not train on hardware the client owns, and we say during scoping which workflows an open-weight model handles well and which it does not. A local deployment does not by itself make a firm compliant with any rule; we build to the controls you already run rather than selling a certification.

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About Black Lily

Black Lily installs private, on-premise AI systems from Philadelphia, Pennsylvania: a complete language model running on hardware the client owns, for hedge funds, registered investment advisers, and family offices whose most valuable documents are the ones they are not allowed to send to an outside service. Founded by William Dorman, Founder & CEO.

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