Agentic-AI Governance, Oversight and Risk.
Standing up the control function agentic work requires.
6 months · fixed-fee, fixed-scope, fixed-deliverable · The chief risk officer or head of compliance
The clinic in brief.
Client-side governance, the weakest gap.
The clinic stands up the control function a bank needs to govern agentic work. Client-side governance was the weakest readiness gap in the study. Governance and responsiveness was a damaging issue in 87 of 150 engagements. Clarity on what agents may do without human approval was the weakest terminal condition of all, at 2.16 on canceled engagements. The clinic installs ownership, decision rights over autonomy, human oversight, the risk and duty registers, and CORAL evidence a regulator would accept.
No control function equal to risk.
- The bank runs agentic work without a control function equal to the risk.
- Ownership of agentic AI is unsettled inside the bank.
- What agents may do without human approval is undefined.
- A regulator, auditor, or board committee has asked a question the bank cannot yet answer from evidence.
Ownership, the three lines, autonomy.
- Accountable ownership. One named owner for agentic AI, under a board mandate.
- The three lines of defense. The first line owns the work, the second challenges and can halt it, the third audits it.
- Autonomy and decision rights. What each agent may do without approval, promoted only on evidence.
- Human oversight. Oversight sized as a control function, with the authority to override an agent in motion.
- The registers. A live risk register, and a non-delegable duty register held in the bank’s own name.
- CORAL evidence. An examiner-ready ledger for Compliance, Oversight, Regulatory, and Legal obligations.
Built in stages, six months.
The clinic runs six months. Akholi assesses the bank against its own adequacy bar rather than a peer average. The control function is built in stages: ownership and registers first, then the three lines and the autonomy controls, then the examiner-ready ledger. Autonomy is capped at the oversight the bank can actually staff.
The registers and the ledger.
One report to the sponsor, and a standing function:
- A prioritized inventory of control gaps.
- A staged plan to stand up the control function across 30-60-90 days and beyond.
- The registers, the decision-rights map, and the examiner-ready ledger.
- The KPIs to hold the line.
Optional — Phil Hatch activation
Phil Hatch can lead the buildout. He chairs the ownership work, installs the registers, and sets the autonomy-to-oversight cap.
The Practice
All clinics →Crisis Response
An engagement in acute failure. Phil Hatch engages the executive team within 24 hours of contact.
Retained Advisory
Standing senior counsel across the outsourcing and global capability center portfolio.