Compliant AI Infrastructure for Regulated Finance: A tiered multi-agent framework with DLT audit trails for financial operations in DACH

Financial institutions are beginning to deploy agentic workflows in credit, fraud, collections, compliance, and operational control. Governance remains largely component-centric: each model or agent is specified, tested, authorized, and monitored locally. That is insufficient when institutional risk arises from the joint behavior of many locally acceptable components. We call this gap constitutional non-compositionality: local compliance checks need not compose into acceptable collective outcomes such as bounded disparate impact, market integrity, or traceable accountability. We propose ARIA as a finance-specific reference architecture and falsifiable research agenda for agent-population governance. It organizes six capabilities across normative-accountability, execution-control, and assurance-learning planes: policy specification, population-level observed-versus-expected behavior monitoring (M2), bounded authority, runtime containment, adaptive policy change, and preserved human oversight competence. Two simulations illustrate shared-signal thin-file exclusion under local controls and earlier warning from observed-versus-expected distributional monitoring in a constructed drift regime. The contribution maps these controls to fair-lending, EU AI Act, model-risk, and conduct-supervision evidence needs, and closes with a validation agenda rather than a production-effectiveness claim.

As large language models (LLMs) are increasingly deployed in financial services, a single non-compliant interaction can expose institutions to regulatory penalties and direct consumer harm. Existing guard models are built around general harm taxonomies and overlook violations grounded in specific financial regulations. We address this gap with a regulation-driven pipeline that operates directly on regulatory documents, inducing a financial compliance risk taxonomy and synthesizing grounded training data without any predefined violation categories. Instantiating the pipeline on Chinese financial regulations, we release \textbf{FinGuard-Bench}, to our knowledge the first benchmark for financial regulatory compliance detection, with expert-annotated labels at both the query and response levels. We further train \textbf{FinGuard}, a financial compliance detection model built on Qwen3-8B and trained on the regulation-grounded data via supervised fine-tuning and self-play reinforcement learning. On FinGuard-Bench, FinGuard substantially outperforms all baselines, including dedicated guard models and much larger general-purpose LLMs such as Qwen3.5-397B-A17B and GPT-5.1. Furthermore, FinGuard also preserves general safety capabilities and adapts to unseen institution-specific policies using policy documents alone. We will publicly release the code, prompts, and resources used in this work on GitHub.

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.