JPMorgan's AI Rules, Sized for Your Business

On Monday, JPMorganChase's Global Technology Leadership Team posted a memo called "200 days into the frontier: What we know and what to do now." The sharpest line is in the first paragraph: "Vulnerability discovery and attack automation are moving at warp speed. Remediation is not."

JPMorgan says that "as companies race to deploy AI agents, security has to advance with it."

The memo, which lays out steps companies should take to mitigate the cybersecurity risks that come with AI, was written for CEOs of big corporations, and it never mentions small businesses. But most of its recommendations scale down to a company with 2 to 100 people.

The first four steps come from the memo's section on AI agents, and “agents” is the word that matters: "Frontier technologies are moving from answering questions to taking action." Translation: a chatbot you paste text into isn't an agent. A tool you've connected to your email, files or accounts — or one that can send, pay or change things — is.

The steps

1. Give each AI tool only what its job needs. The memo: "Access should be based on the task, not on the theoretical reach of the model." When you connect ChatGPT, Claude, Copilot or Gemini to company data, pick the mailbox, folder or account the job needs, not everything. This week, check the list of outside apps connected in your Microsoft 365 or Google Workspace admin console and the connector settings in each AI tool, and remove what nobody uses. Done when every connected AI tool is on a list next to exactly what it can reach.
2. Put a person between the AI and your money, your systems and your customers. The memo: "Human oversight should be proportional to consequence: a reversible, low-impact action warrants a different control than moving money, changing production systems or communicating with a customer." Those three examples are JPMorgan's, and they fit a small business as they are. Let the AI draft the invoice or the email, and have a named person approve before anything gets paid, changed or sent. This week, ask your bank whether it offers a second approver for new payees and wires, and give staff and AI tools an accounting-software role that can draft bills but not pay them. Done when no AI tool can pay a bill or message a customer without a person saying yes.
3. Know every AI tool you've connected, and how to cut one off fast. The memo: "Make agents identifiable, monitor their actions in real time and preserve traceability for investigation and recovery." And: "Maintain the ability to restrict or stop an agent quickly." Real-time monitoring takes tooling most small businesses don't have, so I narrowed this to what you can do: know what's connected, look up what it did and shut it off. This week, write one page listing each tool, who uses it, what it can reach, how to disconnect it and who's allowed to. Then set up a throwaway connection and disconnect it yourself. Done when the page exists and you've used the switch once.
4. Before a tool gets more power, write down what it must never do. The memo: "Capability, however, should not automatically determine authority." And: "Before expanding what agents can do, establish what they cannot do." A new feature isn't a new permission. This week, add a line next to each tool on your page from step 3 saying what it must never do (pay anyone, delete files, email a customer). The memo also says "Reassess boundaries as capabilities, use cases and dependencies change," so re-read the page whenever a tool announces something new. Done when every tool has a "never" line and one person owns re-checking it.
5. List what you own, and put a date on anything the maker stopped updating. The memo: "Start with a complete, current inventory of software and hardware." And: "Unsupported technology should be treated as a time-sensitive business liability." It belongs here because, in the memo's words, "AI magnifies risks accumulated over time," and an old laptop nobody patches is that kind of risk. JPMorgan also wants each exception funded and covered by stopgap protections. I narrowed it to the start: list every computer, phone, router and business app, mark anything that no longer gets security updates (Microsoft ended free support for Windows 10 in October 2025; businesses can still pay for extended updates), and put a name and a replace-by date next to each. Done when nothing unsupported is on the list without both.
6. Decide today who decides in an emergency. The memo: "Teams should not have to invent a decision process during the incident." And: "Define decision rights and emergency authorities in advance so teams can act in hours, not weeks." If somebody steals the bookkeeping login at 8 a.m., nobody should be asking who's allowed to lock it. This week, write half a page: who can shut off an account or an AI tool, who calls the bank and your IT person, and when you switch something off first and fix it after. The memo also says to predefine when an exposed service gets isolated or taken offline, so I added that. Done when it's printed, kept away from the computer it protects, and everyone named on it has read it.

A copy, not the keys

Step 1 usually shows up as a box asking for a password. Bank of America emailed customers asking them never to share their username and password with another person or an outside service, AI tools and agents included. "If you do share your credentials," the email reads, "keep in mind that you're responsible for activity resulting from that access."

That's step 1 from the customer's side. An AI that sorts your transactions or catches a double charge only needs to read your statement, not log in as you. So give it a copy: export the statement as a CSV, delete the account number, and upload that. Check what the tool does with uploads (retention, training) before you send anything about your customers or vendors.

If you want something watching the account every day, use the connection your bank or accounting software already offers, and ask for read-only.

JPMorgan's whole leadership team signed that memo, which probably took at least a month to draft up. Small businesses only need one person and a week to beef up their protections.