Noah Schmidt

Agentic AI in the payments chain: regulatory challenges for financial institutions

AI “agents”, which combine the reasoning of generative AI with memory and execution capabilities, are the next frontier of AI risk and opportunity. One rapidly emerging application is agentic commerce, where agents autonomously execute tasks and make payments – whether operating alone or in multi-agent systems. For financial institutions, the question is not whether agentic commerce will arrive, but whether their existing compliance frameworks can absorb it. This article considers how firms can satisfy regulatory obligations, mitigate risks and allocate liability in this new landscape.