Dynamic oversight for agentic payments: Policy-as-Code and KYC-of-Policy for AI-driven finance

By Dastan Shukanayev

The payments industry is entering a phase in which core decisions are increasingly taken by software agents rather than human operators or static rule engines. Recommendation and optimisation algorithms already influence routing, risk scoring and liquidity management in cards, instant payments and cross-border corridors. ¹ As model-based and agentic systems expand into production, payment providers face a dual challenge: capturing the efficiency and customer experience benefits, while ensuring that emergent behaviours do not erode safety, trust or financial stability. ^{1, 2}