# Governing Agentic AI in FinTech

arXiv: https://arxiv.org/abs/2608.11344 · HTML: https://mlsanity.com/paper/2608.11344/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Placed in Financial trading and forecasting agents, one of 16 directions in LLM agents and tool use.
- Builds on 19 of its 62 references that are in the map.
- First posted on arXiv 11 Aug 2026.

## Placed in

- LLM agents and tool use / [Financial trading and forecasting agents](https://mlsanity.com/agents/financial-trading-and-forecasting-agents/)

## Builds on (most cited first, 19 of 19)

- [Chain-of-Thought Prompting Elicits Reasoning in Large Language Models](https://mlsanity.com/paper/2201.11903/) (2022)
- [ReAct: Synergizing Reasoning and Acting in Language Models](https://mlsanity.com/paper/2210.03629/) (2022)
- ["Why Should I Trust You?": Explaining the Predictions of Any Classifier](https://mlsanity.com/paper/1602.04938/) (2016)
- [On the Opportunities and Risks of Foundation Models](https://mlsanity.com/paper/2108.07258/) (2021)
- [Towards A Rigorous Science of Interpretable Machine Learning](https://mlsanity.com/paper/1702.08608/) (2017)
- [Sanity Checks for Saliency Maps](https://mlsanity.com/paper/1810.03292/) (2018)
- [Language Models Don't Always Say What They Think: Unfaithful Explanations in Chain-of-Thought Prompting](https://mlsanity.com/paper/2305.04388/) (2023)
- [Counterfactual Explanations without Opening the Black Box: Automated Decisions and the GDPR](https://mlsanity.com/paper/1711.00399/) (2017)
- [Model Cards for Model Reporting](https://mlsanity.com/paper/1810.03993/) (2018)
- [The Mythos of Model Interpretability](https://mlsanity.com/paper/1606.03490/) (2016)
- [Measuring Faithfulness in Chain-of-Thought Reasoning](https://mlsanity.com/paper/2307.13702/) (2023)
- [Towards Faithfully Interpretable NLP Systems: How should we define and evaluate faithfulness?](https://mlsanity.com/paper/2004.03685/) (2020)
- [Closing the AI Accountability Gap: Defining an End-to-End Framework for Internal Algorithmic Auditing](https://mlsanity.com/paper/2001.00973/) (2020)
- [Improving Reproducibility in Machine Learning Research (A Report from the NeurIPS 2019 Reproducibility Program)](https://mlsanity.com/paper/2003.12206/) (2020)
- [TradingAgents: Multi-Agents LLM Financial Trading Framework](https://mlsanity.com/paper/2412.20138/) (2024)
- [Harms from Increasingly Agentic Algorithmic Systems](https://mlsanity.com/paper/2302.10329/) (2023)
- [Authenticated Delegation and Authorized AI Agents](https://mlsanity.com/paper/2501.09674/) (2025)
- [Reviewable Automated Decision-Making: A Framework for Accountable Algorithmic Systems](https://mlsanity.com/paper/2102.04201/) (2021)
- [The Accountability Horizon: An Impossibility Theorem for Governing Human-Agent Collectives](https://mlsanity.com/paper/2604.07778/) (2026)

## Abstract (arXiv)

Financial institutions are delegating consequential decisions to agentic AI systems that decompose goals, coordinate models and tools, and act with little oversight. Yet agentic AI governance in FinTech is under-investigated. We argue the binding governance constraint is not capability but verifiability. We define the Verifiability Gap as the shortfall between the verification delegated authority demands and the explainability and reproducibility retained after a decision. It is indexed to a verifier, evidentiary standard, and audit lag. We develop a multilevel governance theory for agentic AI and test its mechanisms in three studies over nine model versions, from a three-billion-parameter local model to a commercial frontier system. Study 1 shows that provider releases alter historical financial actions, and that the controls replay needs belong to the provider: the frontier model rejects temperature, top_p and top_k outright and exposes no random seed. Under the tightest controls each endpoint allows, a local model reproduced 320 of 320 executions, hosted models 319 of 320 and 959 of 960. Study 2 shows that orchestration is a latent policy layer. Architecture changes final actions, and no execution record repeated in any configuration at any scale. The frontier model reproduces its own actions more often than the local ones, its record no better, and loses a comparable share of its differentiation. Capability buys a higher starting point, not auditability. Study 3 shows two deterministic credit-model versions each reproduce their current action perfectly, yet the current cannot recover a historical one. We conceptualize reproducibility as a governance profile, not a scalar, yielding evidence-contingent delegation: authority is defensible only while retained evidence substantiates its exercise. Beyond finance, the framework extends to other high-stakes domains requiring auditability.