✦ RESEARCH INITIATIVE 2025-2026

The Future of AI Governance & Compliance in Financial Services

The financial services industry is deploying AI faster than it can govern it. New research from Zango sets out what the sector needs to close the gap.

Foreword by Lord Clement-Jones

27
Senior risk, compliance, legal & AI governance leaders interviewed
4
Focus groups exploring emerging governance practices
4
Industry roundtables with 60 senior practitioners to validate findings
15
Expert perspectives from across industry and academia
CONTRIBUTORS
Expert perspectives from across financial services and academia
METHODOLOGY
Built on qualitative evidence from senior practitioners.
  • Regional coverage
    UK financial services with broader European representation
  • Sectors covered
    Banking · Fintech · Payments · Wealth management · Digital assets
  • Academic advisers
    University of Glasgow · Oxford Martin School
FOREWORD
“We cannot simply wait for the aftermath of the first major AI-fuelled financial scandal to force us into action.”
  • Lord Tim Clement-Jones, CBE
    Co-Chair, All-Party Parliamentary Group on AI
    House of Lords
EXPERT COMMENTARY
Featured voices from across the industry
Dean Nash
Global COO (Legal)
Rt Hon John Glen MP
Member of the Treasury Committee, House of Commons
Ben Ellis
Chief Compliance Officer
Suzanne Brink
Head of Responsible AI
Ratul Ahmed
Global Head of Model Risk Management & Validation
Iain Laing
Chief Risk Officer
Mitch Trehan
Chief Compliance Officer
Willem Wellinghoff
Chief Compliance Officer & UK Chair
Cosette Reczek
Global Head, Model Risk, Markets
Paul Loftus
General Counsel
Arman Fallah
UK Chief Risk Officer
Archit Chamaria
Chief Data and Analytics Officer
Andrew Sutton
Visiting Fellow
Dr Alessio Azzutti
Lecturer in Law & Technology
Rob Phillipson
Managing Director
✦ WHY THIS RESEARCH

AI is moving faster than the governance frameworks overseeing it

This research set out to understand how financial institutions are governing AI in practice - where frameworks are holding, where they’re straining, and what the next few years will demand of compliance, risk, and legal functions.

It draws on qualitative evidence from senior practitioners across banking, fintech, payments, wealth management, and digital assets - supported by academic advisers from the University of Glasgow and the Oxford Martin School AI Governance Initiative.

  • "If I ask the question - show me everywhere AI is being used across this organisation - I wouldn't be able to get an answer."
    Head of Compliance, regulated financial institution
  • "Think how long it took to build up PPI. That could happen in two weeks with AI - billions of pounds of liability quickly because something wasn't right."
    Director of Compliance, major UK wealth manager

What the research finds

01

A capability gap is emerging in oversight functions.

THE OVERSIGHT GAP
AI adoption is most mature in the first line, where data is structured and the commercial case is clear. Oversight functions are following from a significantly lower base. Those tasked with challenging AI systems often lack the technical literacy to do so meaningfully.

02

AI is reshaping how the Three Lines of Defence operate.

EVOLVING PRACTICE
First-line teams are increasingly running AI-driven validation of their own systems. The second line’s role is shifting from direct model oversight to control oversight- setting the standards for automated validation and exercising judgement when escalation is required.

03

The UK and EU are missing an implementation layer.

AN IMPLEMENTATION GAP
There is currently no authoritative sector-specific guidancetranslating regulatory expectations for AI into operational practice. The US and Singapore have both moved to build this layer through public-private collaboration. The UK and EU have not.

04

Industry shouldn’t wait for regulators.

THE INDUSTRY RESPONSE
Industry should build the answer itself, developing sector-specific guidance modelled on the JMLSG precedent in financial crime in the UK - an industry-led standard, recognised by government, that translates principles into practice.

What’s in the report

01

How AI adoption varies across institution types - and what’s driving the divergence.

02

The six governance models firms are actually using in practice.

03

The impact of AI on how the Three Lines of Defence operates.

04

The AI skills gap, and why this is becoming a governance problem.

05

What a shared AI governance implementation standard should address.

06

The systemic risks of inaction, and how criminals are exploiting the gap.

Receive the full report

The complete findings from interviews with senior financial services leaders on AI governance, risk and compliance.
Full report PDF
Practitioner quotes from 27 senior leaders
Foreword by Lord Clement-Jones
How firms are approaching AI governance today
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✦  WHAT COMES NEXT

Shape the AI governance standard.

The industry needs its own AI governance standard - built by practitioners. A coalition of financial services leaders is building it - modelled on the JMLSG precedent in financial crime. Register your interest in stress-testing it ahead of publication.
Register interest
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