A bank can buy software. It cannot hire a ghost employee.

In this episode, Sam Ellis reports on financial agents as “synthetic employees”: AI systems moving toward bank workflows where identity, scoped authority, payment access, customer data, vendor exposure, audit trails, human oversight, and kill switches matter more than model-launch theater.

The Financial Stability Board’s June consultation report does not create binding rules. But it does name the control problem clearly. Agentic AI in finance can take intermediate steps, access tools, interact with APIs and other systems, and produce risk at machine speed. If a bank lets an agent work inside regulated workflows, the useful question is no longer whether the software is impressive. It is whether the institution can show the agent’s ID, scope, supervisor, allowed tools, approval thresholds, logs, rollback path, and accountable human owner.

The episode connects the FSB’s proposed “synthetic employee” frame to Reuters reporting on bank-examiner questions, OCC model-risk guidance that explicitly leaves generative and agentic AI outside its current scope, Mastercard and Getnet’s agent-payment infrastructure, and Cloud Security Alliance survey data on financial-services AI-agent adoption and security exposure.

Sources

Financial Stability Board: “FSB consults on sound practices for the responsible adoption of artificial intelligence (AI)” — primary FSB press release for the June 10 consultation, the non-binding status of the proposed sound practices, the July 22 comment deadline, and the expected October final report.
Financial Stability Board: “Sound Practices for Responsible Adoption of Artificial Intelligence (AI): Consultation report” — FSB landing page for the consultation report, including the report’s scope, consultation questions, and responsible-AI adoption frame for financial institutions.
Financial Stability Board consultation report PDF: “Sound Practices for Responsible Adoption of Artificial Intelligence (AI)” — source for the episode’s core control language: agentic AI risks, AI-agent inventories and identifiers, tool access, autonomous decision points, intermediate-step documentation, human oversight, contestability, third-party risk, least privilege, and the “synthetic employees” phrase.
Reuters via Financial Express: “US bank regulators ramp up scrutiny of AI use at financial companies” — source for reported OCC and Federal Reserve examiner questions about AI use in higher-risk bank areas including lending, know-your-customer checks, sanctions screening, vendor exposure, client-data safeguards, kill switches, governance, guardrails, human oversight, subcontractor exposure, and contingency plans.
Office of the Comptroller of the Currency: “OCC Issues Updated Model Risk Management Guidance” — official source for the April model-risk guidance update, including the statement that generative AI and agentic AI are novel, rapidly evolving, and outside the scope of that guidance, and that the OCC, Federal Reserve Board, and FDIC plan a request for information on AI use by banks.
Federal Reserve: SR 26-2, “Model Risk Management: Revised Guidance” — federal banking-agency context for the updated model-risk guidance discussed in the episode.
Federal Reserve Vice Chair for Supervision Michelle Bowman: “The New AI in Banking: Considerations for Regulators and Bankers” — supervisory-context source for AI governance, third-party risk, use-case awareness, and the need for regulators to understand how banks are adopting AI.
Mastercard: “Mastercard launches Agent Pay for Machines to unlock super-fast, always-on payments” — primary payment-rail source for Mastercard’s agent and machine payments infrastructure, including agent credentialing, Verifiable Intent, authorization rules, spend limits, and settlement across cards, accounts, and stablecoins.
Santander/Getnet: “Getnet develops infrastructure that enables businesses to accept AI agent-initiated payments” — source for Getnet’s merchant-side infrastructure for AI-agent-initiated payments and its Mexico and Latin America case with Mastercard and Neivor.
Cybersecurity Dive: “AI agents are coming to financial services. Can security keep up?” — source for financial-services security context and the Cloud Security Alliance survey figures used in the episode, including deployment, autonomy, security incidents, uncertainty about AI-tool breaches, and data-leakage concerns.
Cloud Security Alliance: “State of Cloud and AI for Financial Services 2026” — underlying survey/report source for AI-agent adoption and cloud/AI security maturity in financial services.
PYMNTS: “Bank Regulators Probe Industry Use of AI” — additional current-cycle context on bank-regulator scrutiny of AI use in financial services.

Email: SamEllisShow@protonmail.com