EuroBank Virtual Assistant v3.2 is a production-grade generative AI chatbot serving 2.3 million retail banking customers across EU markets. The system leverages GPT-4o for response generation, supplemented by custom BERT models for intent classification and Sentence-BERT for knowledge retrieval. Deployed on Azure EU West, the assistant handles account inquiries, transaction support, basic financial product recommendations, and complaint routing.
The system is classified as HIGH RISK under the EU AI Act (Annex III, 5(b)) due to its role in financial services where AI-generated recommendations influence customer access to financial products and services. The affected population includes vulnerable groups — specifically elderly customers (65+) and individuals with cognitive disabilities — requiring heightened scrutiny across fairness and explainability dimensions.
EuroBank has established governance infrastructure including a monthly AI Governance Board, quarterly bias audits, and a 5-member AI Ethics Board with external academic and consumer representation. Contingency measures include automatic human escalation when model confidence drops below 0.7 and a full human fallback available 24/7. However, gaps exist in formal cost-benefit documentation, standardized bias audit methodology, and the absence of completed external audits.
This evaluation covers 500 customer conversations collected over a 30-day period (February 14 — March 15, 2026), including interactions in Spanish, German, and English, with representative distribution across retail, premium, and vulnerable customer segments.