Doorstep International

Agentic AI controls for financial institutions

Agentic AI needs controls that work outside the model: a defined mandate per agent, an allow-list of tools, transaction limits enforced by the system rather than the prompt, human approval for irreversible or customer-impacting actions, its own least-privilege identity, a tested kill switch, full action logs and manual fallback procedures. Rate agentic use cases high materiality until evidence supports less.

An AI agent plans and executes multi-step tasks: it reads, decides and acts. That turns model error into operational loss, because the wrong action can be executed before anyone sees it.

Why is agentic AI riskier than other AI?

A chatbot that is wrong produces a wrong answer that someone may catch. An agent that is wrong may pay, change a record or email a customer. Errors also cascade: one agent's output becomes another's input. SR 26-2 excludes agentic AI from model risk scope, so the controls have to come from operational risk, information security and the AI policy.

What controls should every AI agent have?

Agentic AI control set and the evidence to keep
ControlWhat it doesEvidence to keep
Mandate and tool allow-listLimits what the agent may do and which systems it may callApproved mandate in the AI inventory; tool configuration
System-enforced limitsCaps values, volumes and counterparties in the platform, not in the promptLimit settings and change log
Human approval gatesRequires a person to approve irreversible, high-value or customer-impacting actionsApproval records with approver identity
Own least-privilege identityAgent runs under a service account, never a staff loginAccess reviews for agent identities
Kill switchBusiness owner or operations can stop the agent immediatelyKill-switch test results
Full action loggingRecords inputs, tool calls, outputs and outcomesRetained, reviewable logs
Manual fallbackProcess continues when the agent is switched offTested fallback procedure
Hand-off validationChecks format, limits and reasonableness between agents and systemsValidation rules and exception reports

How should a bank pilot an AI agent safely?

  • Start with internal, reversible tasks such as reconciliation preparation or document triage.
  • Run the agent in recommend-only mode first and compare its proposals with human decisions.
  • Move to execute-with-approval, then to limited autonomy for low-value actions only when error rates are evidenced.
  • Include agent failure scenarios in operational resilience testing.

Who is accountable when an agent gets it wrong?

The named business owner of the use case, not the vendor or the developer. The FSB and MAS both expect clear roles and human oversight proportionate to risk. Write the owner into the inventory and into the owner's role profile.

Frequently asked questions

What is a kill switch for AI?

A tested mechanism that lets authorised staff stop an AI agent or model immediately, with a manual procedure that keeps the business process running while it is off.

Should AI agents ever act without human approval?

Only for low-value, reversible actions within system-enforced limits, after testing shows acceptable error rates. Irreversible and customer-impacting actions should keep a human approval step.

Put these controls to work this month

Start on the cloud risk management software within 24 hours, or ask for training or advice tailored to your institution.