
AI agents your risk team can sign off.
Reconciliations, document intake and servicing cases are full of keying. We build agents that do the reading and checking in your own Azure tenant, with a named approver on every decision and a log your auditors can read.
| Job | What an agent drafts | Who decides |
|---|---|---|
| KYC and onboarding | Extracted data compared with the application and CIF; missing items requested | The BSA or onboarding analyst; account opening stays human |
| Loan operations | Closing checklist, missing documents, spread financials | The loan officer and closer |
| Reconciliations | Breaks between core, GL, card and ACH matched and explained | Operations, for adjustments |
| AML alert triage | Context gathered and a draft narrative | The investigator decides on a SAR, within 30 days of detection |
| Guidance | What it means |
|---|---|
| SR 26-2 (April 2026) | Replaced SR 11-7 on model risk; generative and agentic AI are outside its scope, so govern agents under your own risk practices |
| Third-party risk (OCC 2023-17) | Still in force; a replacement was proposed in September 2026, comments due 16 Nov 2026 |
| Core providers statement (Sep 2026) | Excessive limits on integrating with the core are a supervisory concern |
| SAR rule | $5,000 threshold; file within 30 days of detection (60 at most); keep 5 years |
From Federal Reserve SR letters and press releases, and the OCC, October 2026.
SR 11-7 was replaced by SR 26-2 in April 2026, which explicitly leaves generative and agentic AI out of scope. Banks should govern agents under their own risk management, with clear human decision points.
Around the core, not in it: onboarding document checks, loan file completeness and reconciliation breaks, with analysts deciding.
No. Agents can gather context and draft narratives, but the decision to file stays with trained investigators, within the 30-day window.
We provide the diligence your third-party risk programme needs under OCC 2023-17, and watch the proposed replacement.
Find out where your team's week goes, with the hours and dollars attached.
Facts on this page checked on 22 October 2026.

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