Build an AI Agent Compliance Program

AI agents that process payments introduce compliance risks that standard compliance programs do not address: velocity risk, opacity risk, and scope risk. This guide covers how to build a program that accounts for all three.

Agent-specific risk factors

• Velocity risk: An agent can repeat a violation hundreds of times in minutes — far faster than any human-operated system.
• Opacity risk: Agent decision paths can be opaque. Was the payment intentional or emergent behavior?
• Scope risk: Agents may interact with counterparties and jurisdictions their operators never anticipated.

The agent compliance program (5 elements)

1. Agent inventory: List every agent with payment authority, what it can spend, and on what.
2. Pre-payment gate: Every payment path includes a sanctions check. Not optional.
3. Spending limits: Per-agent caps on transaction amount, frequency, and total exposure.
4. Real-time alerts: A sanctions match immediately alerts a human and halts the agent.
5. Audit logging: Every screening result is logged with agent identity, timestamp, and outcome.