DFSA Paper Sets Out Four Tests for Agentic AI in Finance
A joint paper with the Cambridge Digital Innovation and Regulation Initiative examines how delegated, tool-using AI changes the speed and traceability of cyber incidents.
The Dubai Financial Services Authority has issued a paper on how frontier and agentic AI could affect cyber resilience in finance, produced with the Cambridge Digital Innovation and Regulation Initiative.
Agentic systems can call on connected tools and act under delegated authority. Work therefore moves faster, and becomes harder to trace once something has gone wrong. The paper sets out what that means for cybersecurity, operational resilience and third-party risk.
It examines resilience through four dimensions: speed, reach, authority and trust. Speed asks whether a firm can safely cut significant cyber exposure before serious consequences occur. Reach asks whether it understands the shared technology and services it relies on, including beyond direct suppliers. Authority asks whether an AI system's actions stay within their intended mandate. Trust asks whether a firm can establish what happened, control unfinished activity and continue or restore critical operations.
Shared models, cloud infrastructure and identity services create dependencies that direct supplier relationships do not always reveal.
Mark Steward, the DFSA's chief executive, said the paper brings together emerging thinking and will prompt wider discussion on how regulators and firms prepare.
Bryan Zhang, co-creator of the Cambridge initiative, said no single firm, regulator or jurisdiction will settle these questions alone. He said he hoped the paper gives the public and private sectors a common vocabulary.
The analysis draws on controlled evaluations, reported cyber incidents and international regulatory work. The DFSA describes it as support for research, not regulatory guidance or a statement of policy.
The framing moves attention away from what a model does in a test and towards what a firm can see and stop while systems are live. Reach is the awkward dimension. Dependencies buried in shared infrastructure rarely appear on a supplier register, and authority lasts only as long as the logging around it.
Steward and Zhang will discuss the paper at the Dubai FinTech Summit on 2 November 2026.
