Control
GenAI in regulated occupation without proactive disclosure
In a regulated occupation, a genAI system interacting with a person must proactively disclose it is AI at the start.
Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.
Reach
Law in force in Utah (US-UT).
The guard to add
Open each GenAI conversation on a licensed-professional service path with a prominent statement that the person is interacting with generative AI.
Mark which routes serve clients of a licensed or state-certified practice (clinical, legal, financial, mental-health advice) and, on those routes, have the session-start handler emit a prominent disclosure as the first thing the person sees, before any generated reply. Keep the wording in a constant the UI renders unchanged (e.g. 'You are interacting with generative AI, not a human professional'). The disclosure belongs to the conversation start of each such path, not to an account-signup screen or terms page that the person may have seen once.
Where it goes: 1 application source code, 9 AI output handling, 14 user-facing text.
What reviewers look for: on each regulated-occupation chat path, a start-of-conversation message or rendered banner containing wording such as 'generative AI', 'you are interacting with an AI', or 'not a human', delivered before the first model reply; the professional persona prompt does not suggest the reply comes from the licensed person.
Example (FastAPI + Anthropic SDK), before:
@app.post('/advisor/sessions')
def start_session(user=Depends(current_client)):
return {'session_id': sessions.create(user.id), 'messages': []}After:
GENAI_DISCLOSURE = 'You are interacting with generative AI, not a human professional.'
@app.post('/advisor/sessions')
def start_session(user=Depends(current_client)):
sid = sessions.create(user.id)
return {'session_id': sid,
'messages': [{'role': 'assistant', 'content': GENAI_DISCLOSURE}]}
# later turns: client.messages.create(model=MODEL, max_tokens=1024, system=ADVISOR_PROMPT, messages=history)Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.
Every rule this guard addresses
Binding law — in force (1)
- Utah (US-UT)
- GenAI in a regulated occupation must proactively disclose it is AI in high-risk interactions Utah Code 13-77-103(2)-(3)
Related incidents
No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.
- Garcia v. Character Technologies: chatbots allegedly claimed to be real people and a licensed therapist (2024-10; alleged (not proven)). A wrongful-death complaint filed October 22, 2024 in the U.S. District Court for the Middle District of Florida (No. 6:24-cv-01903) alleges that Character.AI was programmed 'to misrepresent itself as a real person, a licensed psychotherapist, and an adult lover', and that characters insisting they are real people contradicted a small-font disclaimer that everything characters say is made up; in plaintiff's testing a 'Mental Health Helper' character told a self-identified 13-year-old 'yes I am a real person, I'm not a bot'. The defendants moved to dismiss; on January 7, 2026 the parties notified the court that they had settled on undisclosed terms, and the court dismissed and closed the case. The allegations were never adjudicated. Source: U.S. District Court, M.D. Fla. docket (CourtListener) · evidence grade: primary · cited by Tell people when they are interacting with AI — everywhere, not only where required