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Research into two-party agentic delivery

Retained Accountability Papers

Buyer duties and authority that persist when execution is delegated.

Phil Hatch / AkholiExplore the full study →
Title page: Critical Third Party Oversight and the Bank’s Retained Duty — A Board Review of Agentic Service Dependencies. Phil Hatch, Akholi, October 23, 2026.

AAO-008 / Regulation and Compliance

Critical Third Party Oversight and the Bank’s Retained Duty

Direct oversight of critical technology suppliers does not establish that a bank’s own agentic service is governed or recoverable. Directors should require a dependency review connecting the primary provider to the bank’s actual business service.

Buy-side Boards and Executives
Asset and Wealth Management · Banking · Financial Services · Insurance · 5 pages
Title page: Governing Agentic AI Beyond Model Risk Guidance — Bank Control Coverage Under SR 26-2. Phil Hatch, Akholi, October 23, 2026.

AAO-001 / Regulation and Compliance

Governing Agentic AI Beyond Model Risk Guidance

US bank leaders should require a complete control coverage decision for every outsourced agentic service. Exclusion from model risk guidance leaves the bank with a governance task that a provider model review cannot settle.

Buy-side Boards and Executives
Banking · Financial Services · 5 pages
Title page: Bank Governance, Oversight, and Controls for Agentic Outsourcing — The Immediate Audit. Phil Hatch, Akholi, October 23, 2026.

AAO-121 / Governance and Accountability

Bank Governance, Oversight, and Controls for Agentic Outsourcing

Every one of the study’s 150 engagements contained a reported departure from intended governance, oversight, or control functions. Bank boards should commission an independent audit of delivery, contain material exposure, and require evidence that corrections operate.

Buy-side Boards and Executives
Banking · Financial Services · 10 pages
Title page: The Board Audit for Agentic Outsourcing — Four Findings Require Immediate Examination. Phil Hatch, Akholi, October 23, 2026.

AAO-126 / Assurance and Audit

The Board Audit for Agentic Outsourcing

Reported control departures and manual alteration each reached 150 of 150 sampled engagements. The manual-alteration contrast is 100% of engagements versus under 1.3% of pooled disclosure answers. Bank boards should commission an independent portfolio audit covering provider delivery and the bank’s own readiness.

Buy-side Boards and Executives
Banking · Financial Services · 8 pages

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