Banks on the hook for agents’ actions, OCC says

The Office of the Comptroller of the Currency has told its examiners not to treat AI — or super intelligence as the government calls it — as a risk category of its own, instructing them instead to fold banks’ use of AI and agentic systems into supervisory frameworks already governing every other technology. In a framework issued Nov. 4 for its examination workforce — which the regulator frames around banks’ use of AI and agentic AI — the OCC said examiners “should not treat SI as a separate and distinct risk category,” and that banks “should not be required to define a separate SI risk appetite.” [caption id="attachment_57387416" align="alignright" width="311"] Courtesy/Bloomberg[/caption] The approach, it said, is technology-neutral. The guidance tracks closely with the United Kingdom’s Financial Conduct Authority , which issued an analogous paper Oct. 19. “There’s a very broad alignment between the OCC and the FCA,” said Andrew Bud , chief executive of biometric firm iProov , noting both regulators treat the issue as outcome-driven and put human oversight at the center. “The greater the level of human interaction with what agents are actually doing, the lower the risk,” Bud said. The throughline of the framework is accountability — and it stays with the bank. “Bank management still owns it,” said Prescott Ford , a principal at consultancy SolomonEdwards and a former OCC examiner, told FinAi News . “It’s not a black box. It’s management’s box. Bud added: "You can’t hold an agent accountable” the way you can an employee. Human oversight, blast radius That puts a premium on human oversight — but not on reviewing everything, Bud said. “You can’t have humans in the loop reviewing every step,” Bud said. Instead, humans should sign off on high-risk actions, judged by consequence, reversibility and exposure, or “blast radius.” Overdo it, Bud warned, and banks invite “consent fatigue,” where overloaded approvers “just go, ‘yeah, whatever’” — a quiet erosion of the very control the framework demands. Approving a request for a $500 credit limit increase has a smaller blast radius than approving a $100,000 loan application, he said. Future look The OCC directive is guidance — not law — a point that matters as a new Congress reshapes the agenda. Annie DeStefano , founder of Ann DeStefano Advisory , told FinAi News that she expects AI supervision to converge with a revived consumer-protection push rather than stand alone. Banks, she added, “have already started … adapting AI risk to their existing risk frameworks, which I think ultimately is where this is going to land.” What the framework does not address, Bud said, is an emergent risk from large “swarms” of agents acting together. Each step looks benign, but the sum of their work does not. Separate agents doing KYC, money movement and AML checks can make mistakes that can be overlooked, he said. “None of those actions … looks particularly high risk,” he said. "Put them all together and you’ve ended up with a … high-speed money-laundering machine.” The OCC said it will update the framework as the technology evolves, but no guidelines have been provided. The agency did not respond to a FinAi News request for comment before publication. Register here for early-bird pricing for the FinAi Banking Summit, taking place March 1-2 in Denver. View the full event agenda here .

Banks on the hook for agents’ actions, OCC says

Guidance does not mention how to handle swarms of agents

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Banks on the hook for agents’ actions, OCC says

Guidance does not mention how to handle swarms of agents

U.S. Bank launches Protect 360 to find, help remediate personal data risks

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