Risk & Compliance | Banking & Fintech | Payments & Digital Assets | Views my own

Joined March 2011
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I'm very happy to share a new article — "In Defense of the Second Line of Defense: The Role of Independent Risk Management" — just published in the 2023 Starling Compendium. To access, click through, choose join, and "Observer Status" (which is free). insights.starlingtrust.com/c…
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"On innovation, the Federal Reserve has emphasized a transparent, risk focused approach that supports responsible technological advancement while reinforcing core supervisory principles. … The [Statement of Supervisory Operating Principles] included a number of principles designed to strengthen supervision. Among other things, it directed examiners to focus their attention on deficiencies that created a significant threat to a firm's safety and soundness and to give less priority to procedural or documentation shortcomings." federalreserve.gov/publicati…
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"Following the implementation of the revised [Large Financial Institution] rating system, which became effective on January 16, 2026, the proportion of large financial institutions considered 'well managed' increased based on the revised definition of 'well-managed.'"
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"Blockchain and crypto asset technologies have the potential to revolutionize America's financial infrastructure and deliver new optionality, efficiencies, cost reductions, transparency, and risk mitigation for the benefit of all Americans. The rapid growth in these areas has outpaced the existing regulatory framework. A clear and consistent approach is needed to provide legal certainty for innovators while protecting investors and preserving market integrity." sec.gov/files/draft-strategi…
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"It is important that, going forward, we ensure that there is a path to responsible innovation in the banking system, including in the use of AI." federalreserve.gov/newsevent…
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"Some steps that financial institutions take for human oversight of GenAI and agentic AI include ... placing boundaries on AI agents, such as defining actions that are prohibited or that require human approval at appropriate checkpoints (i.e. high risk actions or steps outside of the agent’s initial human-defined scope)." fsb.org/uploads/P100626.pdf
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The FSB's list of 12 sound practices for financial institutions’ responsible AI adoption (Annex 1 of the report)
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"These reporting forms would help ensure compliance with the proposed rule, facilitate OCC supervision of permitted payment stablecoin issuers and foreign payment stablecoin issuers, and would promote transparency with respect to the financial condition of permitted payment stablecoin issuers and foreign payment stablecoin issuers." occ.gov/news-issuances/bulle…
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"Respondents identified a broad range of AI‑related risks to their own operations, but three risk categories dominate: data quality and bias, cyber security and data privacy, model risk or lack of explainability." — Bank of Canada, Financial System Survey Highlights bankofcanada.ca/2026/05/fina…
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"Human oversight [:] AI should support cyber defenders, not replace human judgment, particularly where decisions could affect high consequence cyber or safety environments." cyber.gov.au/sites/default/f…
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"Agentic AI systems offer powerful automation benefits, but their ability to act autonomously across interconnected tools, data and environments introduces security risks that extend beyond those associated with traditional software or GenAI." cyber.gov.au/sites/default/f…
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"AI governance gaps persist everywhere In every sector and jurisdiction, the deployment of AI-driven decision systems has outpaced governance frameworks. ... no jurisdiction has fully resolved how existing regulatory obligations apply to automated decisions." download.asic.gov.au/media/b…
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From the report, "Comparative overview of technology-enabled regulatory and supervisory solutions across major jurisdictions"
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"...responsible adoption of tokenisation in the UK can enhance financial stability and support sustainable growth – not only in retail payments but also, especially given this audience, in financial markets and the services they provide to the UK and global economies." bankofengland.co.uk/speech/2…
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"The totality of our experience with AI leads us to the conclusion that, alongside experimentation, strong governance and risk management must be our foundation. The most promising approaches augment human judgment with AI capabilities while building verification into the architecture itself." The Opportunities and Risks AI Presents for the Economy and Financial System federalreserve.gov/newsevent… via @FederalReserve
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"Tokenisation using blockchain technology can significantly enhance cross border payment workflows. The prototype shows how processes that are traditionally fragmented can be integrated, enabling the coordinated crediting and debiting of multiple accounts" bis.org/publ/othp110.htm via @bis_org
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"Artificial intelligence (AI) is being adopted rapidly across all regulated industries, creating opportunities for efficiency and innovation. However, governance arrangements have not matured at the same pace. APRA has recently reinforced its expectations for sound AI governance and risk management via a letter to industry." apra.gov.au/system-risk-outl…
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"This report responds to that need by providing IOSCO member authorities with a supervisory toolkit to support risk-based and proportionate oversight of AI systems used by supervised firms." Link: iosco.org/library/pubdocs/pd…
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From the report, Controls and Human Oversight of AI Systems (excerpt from Table 3)
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