Felix Shipkevich Discusses AI Agent Liability and Financial Regulation in Sandmark

Shipkevich PLLC founder and principal Felix Shipkevich was recently featured in Sandmark’s examination of one of the emerging legal questions surrounding artificial intelligence: what happens when autonomous AI agents are given the ability to control assets, execute transactions, and move money?

AI agents are quickly evolving beyond systems that simply generate text or provide information. New applications are being designed to interact with financial infrastructure, manage digital wallets, execute trades, and carry out transactions with increasingly limited human involvement.

In its feature, “AI Agents Can Move Money – Lawyers Say Nobody Knows Who’s Liable,” Sandmark examines the legal and regulatory questions that arise as AI systems gain greater financial autonomy.

Felix Shipkevich contributed his perspective to the discussion, bringing experience at the intersection of financial regulation, payments, digital assets, and emerging technology.

When AI Can Act, Who Is Responsible?

The development of autonomous financial agents presents a fundamental legal question: Who is responsible when an AI agent makes a financial decision that causes a loss or violates the law?

The answer becomes increasingly complicated when several parties are involved.

An AI agent may rely on a model developed by one company, operate through software created by another, connect to a third-party financial platform, and ultimately act on behalf of an individual or business.

Determining responsibility may therefore require examining who authorized the activity, who maintained control over the system, how the agent was designed, and what safeguards were in place.

These questions become particularly significant when an AI agent is no longer merely recommending an action, but actually executing it.

AI Agents Meet Financial Regulation

Giving AI agents the ability to move money also raises regulatory questions beyond traditional technology liability.

Depending on how an agent is structured and what activities it performs, existing financial laws involving payments, money transmission, securities, digital assets, consumer protection, and other regulated financial activities may become relevant.

This is an area closely connected to Shipkevich’s practice.

As founder and principal of Shipkevich PLLC, Shipkevich advises financial institutions, fintech and digital asset companies, payments firms, and other financial services businesses on regulatory, transactional, licensing, and enforcement matters.

The rise of autonomous financial agents adds a new layer to those existing regulatory frameworks.

Existing Laws Were Not Written for Autonomous Agents

One of the challenges highlighted by the emergence of agentic AI is that many financial laws were created around transactions initiated by identifiable individuals or businesses.

An autonomous AI agent complicates that model.

The agent itself is not a legal person, yet it may be capable of initiating an action with real financial consequences. That creates questions about how existing concepts of authorization, agency, control, negligence, and responsibility should apply.

For companies developing or deploying these technologies, the absence of a single AI-specific liability framework does not necessarily mean there are no legal obligations.

Instead, businesses may need to evaluate how existing financial regulations apply to new technology that operates in ways those regulations did not originally contemplate.

Control Could Become a Critical Question

As AI systems become more autonomous, understanding who retains control over their actions may become increasingly important.

Businesses deploying financial AI agents should consider issues such as the scope of an agent’s authority, transaction limits, human approval requirements, monitoring procedures, security controls, and the ability to stop or reverse activity.

These safeguards may become especially important when AI agents interact directly with payment systems, digital assets, investment platforms, or customer funds.

The legal analysis may ultimately depend less on whether something is labeled an “AI agent” and more on what the technology is actually permitted to do.

Preparing for the Agentic Financial System

The development of AI agents capable of conducting financial transactions represents another example of technology advancing faster than the legal frameworks surrounding it.

For fintech companies, payment providers, digital asset businesses, financial institutions, and AI developers, that makes proactive legal and compliance planning increasingly important.

Companies exploring autonomous financial systems should consider how existing licensing requirements, financial regulations, contractual relationships, consumer protections, and internal controls apply before granting AI systems meaningful authority over financial assets.

Shipkevich’s participation in Sandmark’s discussion reflects the growing intersection between artificial intelligence and financial regulation — and the increasingly complex legal questions businesses will need to address as AI moves from providing information to taking action.

Read the full Sandmark feature, “AI Agents Can Move Money – Lawyers Say Nobody Knows Who’s Liable,” for the broader discussion of AI agents, financial transactions, and the developing liability landscape.

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