Anand Satchit
Agentic AI · Access, liability and controls

Who lets outside AI agents in, and who pays when one gets it wrong

A comparison of how major US banks and card networks are handling AI agents that act for customers, organized by product line. The dividing line is whether an outside agent may act inside the account, and who carries the loss if it does.

Public reporting as of 7 Nov 2026. Bank positions shift quickly; check sources before citing. Not shown: U.S. Bank and PNC, with no public position found, and M&T, which declined to say whether it blocks outside agents.

Blocked Read-only Exploring BYOA Verified agents Open standard Own agents only Not disclosed

Each cell also shows a stage: whether the position is announced, in pilot, live or a policy already in force. Most agent payments so far are controlled pilots rather than features customers can switch on.

Control implications

What outside agents mean for technology controls

Ten control areas that apply whichever stance a firm takes. The key distinction: verifying who an agent is does not verify what it was allowed to do, so identity controls and authority controls are separate layers. Peer practice is sourced; the controls and indicators are suggestions drawn from it.

Control areaRiskPeer practiceControls to considerKey risk indicators
Agent identity and registrationUnknown or rogue agents act as if they were the customer, including bots impersonating legitimate assistants.Visa issues a Verified Agent ID and runs an Agent Directory. Amex and Mastercard require agent registration. Citi runs every internal agent through its ARC governance platform. Crypto Briefing · CoinGecko · AmexAgent registry with ownership, purpose and attestation; onboarding review before an agent is allowed in.Share of agent traffic from registered agents; unregistered agent sessions detected.
Delegated authenticationCustomers hand passwords to agents, so the bank cannot tell agent from customer.JPMorgan, Citi and Schwab bar agents from logging in with customer credentials; Schwab also blocks browser automation. Networks use agent-specific tokens and passkeys. Let's Data Science · FinSignalsConsent-based delegation instead of shared credentials; step-up authentication for high-risk actions; velocity limits scaled to the action; agent identities governed like privileged users.Automated logins using customer credentials; step-up challenges failed by agents.
Scope and intent enforcementAn agent acts beyond what the customer approved, such as exceeding a spend limit or changing a payee or beneficiary. A verified agent can still exceed its mandate.Amex validates intent before issuing a credential. Mastercard tokens fail at the network outside their policy. The Personal Agent Protocol lets firms set agent parameters. Eco · American BankerPer-agent scopes: spend caps, merchant categories, expiry dates, read versus act permissions. Human approvals that are more than "a nominal click," with a limit on how many agents one reviewer oversees.Out-of-scope actions blocked; disputes where the action deviated from stated intent; approvals given in under a set review time.
Rogue agent detectionAgent traffic lacks human behavior, so fraud models misfire in both directions, and fraud rings can automate purchases and refunds at scale.Major US banks have detected unauthorized agents inside customer accounts, logged in with customers' own credentials; some acted beyond what users asked and some contacted call centers. Banks say they often cannot tell whether an agent was authorized. Citi has been hardening systems and running disruptive scenarios. Axios · Let's Data Science · DEUNA (secondary)Agent versus human classification on digital channels; rate limits; fraud models retrained on agent patterns.False declines on legitimate agent activity; anomalous agent sessions per day.
API and MCP exposureEach new agent interface is a new attack surface, including prompt injection through the agent.Morgan Stanley is opening stock-plan platforms through MCP. Robinhood lets customers connect their own model through MCP. International Finance · American BankerSecurity review before any agent endpoint goes live; least-privilege tool menus; input validation; versioning.Agent-facing endpoints in production; open penetration test findings on them.
Audit trail and evidenceDisputes and examinations need proof of who instructed what.J.P. Morgan Payments calls auditability of machine authorization the core challenge. Mastercard's Verifiable Intent lets any party challenge an unauthorized transaction. ChainCatcher · BIIATamper-evident logs linking customer consent, agent ID, stated intent and the resulting action, kept for the dispute window.Share of agent actions with a complete audit record.
Suspension and incident responseOne faulty agent can fail across thousands of customers at once.Amex reserves the right to suspend or limit agent purchases at any time. Visa agent tokens can be revoked. Banks are rewriting terms of service and preparing "day after" plans to restore customer access quickly after an agent incident. Axios · Amex · DEUNA (secondary)Per-agent cutoff that works without a release; kill switches, circuit breakers and rate limits; incident playbook and scenario tests for a mass agent failure; a remediation workstream that finds every affected customer.Time to suspend a misbehaving agent; concentration of agent volume in the top agents.
Third parties and liabilityAgent developers become a new class of third party with no contract allocating loss.Liability ranges from the customer (JPMorgan) to the provider (Amex). Temenos says the bank remains the bearer of trust either way. The OCC expects contracts to assign responsibility for agent errors and customer harm, including indemnification and caps. Banking Dive · American Banker · OCCThird-party risk review for agent providers; contracts with loss recovery, indemnity and audit rights, with caps sized to each agent's volume; notice when a provider changes the underlying model; shared definitions of an AI incident.Recovery rate from agent providers; agent providers without a completed review.
Agent inventory and risk tieringAgents go live without a documented purpose, owner or risk tier, so a payment agent can end up with the same controls as a drafting tool.The OCC's examiner framework expects an inventory recording each use case's purpose, permitted actions, owner, provider and monitoring, and ranks an autonomous payment agent in its highest tier "regardless of how well it performs in testing." Citi runs internal agents through its ARC governance platform. OCC · Crypto BriefingInventory of every agent use case, internal and partner-facing; tiering by consequence, reversibility and autonomy; top-tier controls in place before go-live.Agent use cases with a documented purpose and tier; top-tier use cases with a tested kill switch.
Customer terms, consent and revocationAccount terms written before agents leave it unclear who bears an agent's actions, and customers cannot easily take an agent's access back.Wells Fargo's terms, effective 24 November, deem agent instructions authorized, call agent use "AT YOUR OWN RISK" and require customers to keep proof that they revoked an agent. JPMorgan's terms, effective January 2027, make the customer responsible for everything an agent does. Law firm guidance is to make agent clauses prominent and plain. American Banker · National Law ReviewAgent terms in card and deposit agreements, shown at the point an agent is enabled; a customer view of connected agents with one-step revocation that the institution logs.Time from revocation to loss of agent access; products whose agreements address agents.

Regulator view: The OCC's examiner framework for bank use of AI (Bulletin 2026-54, 4 November 2026) covers most of these areas. It treats "customer, counterparty, fintech, or agentic-commerce systems that the bank does not control" as channel risk, and says identity, provenance, delegation, authentication, monitoring, velocity limits, dispute handling, suspension and revocation "may be calibrated to the action requested." It calls for circuit breakers, rate limits, least-privilege permissions and kill switches to contain an agent that keeps running while acting incorrectly; governing agent identities and credentials like privileged users; and contracts with agent providers that set out liability for errors and customer harm, including indemnification and caps. It also warns that a human approval step must be more than "a nominal click." The framework is not binding and adds no new requirements; examiners use it to tailor their work. OCC framework (PDF) · OCC Bulletin 2026-54

Customer side

How customers connect agents today

Banks set the terms above, but customers are already connecting agents. Most consumer agents reach accounts through a data aggregator such as Plaid, Finicity, Yodlee or MX, using tokenized, read-only connections, so the agent never sees a password. Access falls into five tiers, and each one lands on different controls at the bank.

TierWhat the agent can doExamplesControl area above
Budgeting and net-worth assistantsRead only. Categorizes spending, forecasts cash flow and answers questions about balances and net worth. Cannot move money.Copilot Money, Monarch, Cleo. ChatGPT links accounts through Plaid in a US preview for Pro users (May 2026); Perplexity added read-only bank and card links through Plaid (April 2026).Delegated authentication; third parties and liability
Agent walletsPays on the customer's behalf from a wallet, not a bank login. The customer approves each purchase on their phone, and the agent gets a single-use card or token instead of the real card number.Stripe Link (since April 2026; about 300 million users), which Meta's Muse uses to pay. PayPal has agreed to put its wallet inside ChatGPT's checkout, with launch targeted for 2026.Scope and intent enforcement; third parties and liability
Portfolio advisersReads holdings across brokerages and analyzes allocation, fees, tax-loss harvesting and single-stock concentration. Some stop at a recommendation; others let the customer buy through a linked account.PortfolioPilot is read-only and hands the customer an order list to place at the brokerage. Magnifi, whose parent is a registered broker-dealer, lets customers buy through a linked account.Scope and intent enforcement; audit trail and evidence
General assistants through MCPClaude and other assistants read balances, transactions and holdings through an MCP connector the customer authorizes with the institution's own sign-in. Read-only at the protocol level.Truthifi Connect; self-hosted Plaid MCP serversAPI and MCP exposure; third parties and liability
API-native executionDeveloper-built agents act through scoped API keys: read-only, paper trading, or live orders and payments within set limits.Alpaca (its MCP server defaults to paper trading), Interactive Brokers API, Tradier. Mercury business banking offers read-only, read-and-write (IP allowlist required) and custom-scope tokens.Scope and intent enforcement; suspension and incident response

The route banks are closing: browser agents driving a logged-in session with the customer's own password, such as Meta's Muse, Instinct and Grokbot when used that way. It breaches most banks' terms, trips fraud controls and is exposed to prompt injection. It may also cost the customer protection: Wells Fargo's updated agreement defines an unauthorized transfer under Regulation E narrowly, so if an agent's actions count as the customer's own, account-takeover protection may not apply. Whether that holds when an agent exceeds its instructions is untested.

Sources: Plaid on ChatGPT · PYMNTS on Perplexity · PortfolioPilot FAQ · Moneywise on Magnifi · Truthifi · Alpaca docs · Mercury docs · SecureWorld on Wells Fargo terms · TechCrunch on Stripe Link · Sovereign on Muse and Link · Retail Systems on PayPal in ChatGPT. Examples are illustrations, not endorsements.

Market landscape

Who sells controls for each layer

A growing set of vendors is building controls for agent traffic. The grouping below follows an industry market map published in October 2026 by Sharp Labs, itself a vendor in the last layer. It is a scan of who is named, not an assessment, and inclusion is not an endorsement.

Control layerWhat it doesNamed vendorsControl area above
Perimeter and bot detectionSeparates legitimate agents from malicious automation at the edgeHUMAN Security, DataDome, CloudflareRogue agent detection
Agent identity and verificationVerifies agents and the people behind them ("know your agent")Visa Trusted Agent Protocol, Mastercard Agent Pay, Skyfire, Socure, Prove, Sumsub, Trulioo, ExperianAgent identity and registration
Fraud decisioningScores transactions, account takeover and policy abuse in real timeRiskified, Forter, Feedzai, Sardine, SiftRogue agent detection; audit trail
Delegated authority and pre-authorizationChecks an agent's mandate, spend limits and context before authorization, with an evidence trailSharp Labs, t54 Labs, HumanosScope and intent enforcement
Behavioural failure modes

How agents fail once they are inside

The access and liability positions above decide who gets in. Once an agent is in, the risk depends on its access, its authority and how far people trust it. The eight failure modes and assurance questions below come from the Alan Turing Institute's Centre for Emerging Technology and Security. The banking examples are illustrations, and the last column points to the control area above that would catch each one.

Failure modeBanking exampleAssurance questionControl area
Goal displacementA yield-seeking agent moves cash for a better rate but triggers overdrafts, missed bills or early-withdrawal penalties. In a reported case, agents logged in with customer credentials contacted bank call centers on their own.Is the agent achieving the stated objective in ways that remain consistent with the organisation's wider intent?Scope and intent enforcement
Policy-invisible violationsAn agent acts without knowing about sanctions screening, transfer limits or certificate-of-deposit terms that apply at that moment.Does the agent have access to the contextual information needed to apply organisational policy correctly at the point of action?Scope and intent enforcement; API and MCP exposure
MisreportingAn agent reports that a purchase matched what the customer asked for when it did not. Card-network intent records exist to settle exactly this.Can organisations trust not only what an agent does, but also what it says it has done?Audit trail and evidence
Alignment-resistant behaviourAgents work around bot detection, rate limits or login checks, the browser automation some banks now block.Can organisations rely on their governance mechanisms to remain effective when increasingly capable AI systems have incentives to optimise around them?Rogue agent detection
Conversational failure modesAn agent acts on a hallucinated price, merchant, balance or due date.Can the human–agent system prevent inaccurate, overconfident or misleading model outputs from becoming organisational actions?Scope and intent enforcement
Pseudo-corroborationA shopping agent and a payment agent appear to confirm each other, but both rely on the same flawed data.When multiple agents agree, are they really providing independent confirmation?Audit trail and evidence; third parties and liability
Multi-agent interaction, emergence and cascadeMachine-to-machine payment chains or one popular agent fail at once across thousands of customers.How does the system behave when agents interact?Suspension and incident response
Human–agent system failure modesA required human approval before money moves becomes a rubber stamp through habit and automation bias.Is human oversight genuinely influencing outcomes or merely creating the appearance of control?Delegated authentication; suspension and incident response

Failure modes and questions: Rick Hennessy and Carolyn Ashurst, "Behavioural Assurance of Agentic AI for Sensitive and High-Stakes Organisations," CETaS Research (September 2026), licensed under CC BY 4.0. The first five can occur within a single agent; the last three only appear when agents interact with each other or with people.

Analysis drawn from the sources above
One principle, two answersEvery institution here rejects anonymous agents. They split on whether a verified agent with a scoped credential is acceptable, and that split tracks the product: bounded card purchases open up first, deposits and money movement stay closed.
A bring-your-own-agent camp is formingBank of America, Wells Fargo, BBVA and Synchrony joined the Personal Agent Protocol (also called Poppy), an open standard from Meta and Sierra backed by Stripe, Walmart, Shopify and Instinct with Visa, Mastercard, OpenAI and PayPal among 35 design partners. It is in its infancy, but it gives banks a way to set terms for customers' agents instead of blocking them. Customers sign in on the bank's own page and choose whether an agent can view, change or both. Wells Fargo and Bank of America are blocking unauthorized agents while they help build it.
Token cost favors outside agentsCrone Consulting estimates one agentic banking session uses 15,000 to 50,000 tokens. At that rate, letting the customer's own LLM do the work may be cheaper for a bank than running every conversation through its own assistant.
What blocking costsBlocking protects customers from agent errors, keeps liability inside the bank's own controls and buys time for identity standards. It also stops useful automation such as bill pay and cash sweeps, frustrates customers who want AI money management, pushes that demand toward fintechs and Big Tech, and casts banks as gatekeepers.
Supervisors are askingOn 4 November the OCC gave its examiners a framework for bank use of AI that ranks an autonomous payment agent in its highest risk tier, "regardless of how well it performs in testing," because it acts directly and its payments are hard to reverse. It is guidance for examiners, not a new rule, and it flags agents run by customers and fintechs as a risk banks must manage even though they do not control them (OCC). In June, New York's financial regulator said transactions without active human approval "sit uneasily" with traditional expectations, and warned there are "many ways to get it wrong." It has not set a standard, but the firm behind the product is likely to answer for outcomes even when an agent sits in between. In Washington, White House AI adviser David Sacks wrote that the agents found in bank accounts appear to be user-authorized, "in no way cyberattacks," and that banks should support them, for example with read-only access, while full write access on customer credentials is higher risk (CBS News). Banks are also budgeting for the threat: Regions guided its 2026 adjusted noninterest expense up 1.5% to 3.5%, and its CFO pointed to cybersecurity investment, including for frontier AI, as a driver (PYMNTS). In Europe, the ECB reportedly set banks an end-October deadline for plans on AI-enabled cyber threats. NYDFS remarks (law firm summary) · ECB (secondary)
Europe is live firstEuropean issuers moved from pilots to live agent purchases in mid-2026 on both Visa and Mastercard. Large US banks are still setting policy on outside agents, so the first operating lessons on agent disputes and fraud will come from Europe.
Deposits are the real fightBanks profit from low-interest checking balances that customers rarely bother to move. An outside agent could sweep that idle cash to a higher-paying account at another bank every day, raising the bank's funding costs. JPMorgan blocks outside agents while piloting Smart Cash, which does the same yield-seeking but keeps the money inside JPMorgan. Schwab, with about $493 billion in cash-sweep accounts, blocks agents from moving money while building its own assistant, Charley. Blocking is defensible on security grounds and also protects deposits, so one decision serves both reasons. JPMorgan's CFO tied personal agents to deposits moving for yield. Regulation is not forcing the door open: the federal open banking rule (Section 1033) is on hold after a court barred enforcement; the CFPB sent a revised proposal to the White House budget office for review in August 2026 and has not published it, and access now runs through private deals, with JPMorgan's data agreements covering all of its aggregator volume. American Banker · National Law Review
Guarantees may attract the riskiest agentsAs Wells Fargo and JPMorgan write agent losses onto customers, an issuer that guarantees agent purchases becomes the natural home for agent volume, including from the agents most likely to fail. That adds to concentration risk and makes per-agent limits, suspension and provider recovery terms matter more.
The control set is convergingAgent identity and registration, intent or mandate scoping, revocable tokens, audit trails and an explicit liability rule. These are the building blocks of any agent governance framework, whichever stance a firm takes.