The Real Risk in AI Payments Isn’t the Model but the Gaps Around It

AI governance is not a one-time decision; it is an ongoing discipline and a continuously evolving effort, i2c CEO Amir Wain writes in a new PYMNTS eBook, “AI Runs Payments. Governance Decides What Happens Next.”

Artificial intelligence is no longer just influencing decisions in payments — it is starting to make them. And the pace of that shift is accelerating faster than most institutions are prepared to govern. There has never been a technology where development and adoption have occurred at the rate we are now seeing with AI.

That acceleration brings both opportunity and risk. On one hand, it has the potential to be a great equalizer, giving small and mid-sized institutions the ability to compete with much larger players. But it is also a threat. On the other hand, it forces a more urgent question: if AI is acting, who is accountable?

To answer that, it helps to step back. When I think about AI in payments, I don’t start with the model — I start with the system. Architecture ultimately determines the destiny of the business.

For years, the industry has relied on a fragmented approach — stitching together different systems to solve business problems across credit, debit and core banking. Over time, that fragmentation created gaps. When AI is introduced into that environment, governance doesn’t fail at the model level — it fails in the gaps between systems, decisions and ownership.

That realization led to a different architectural choice: building a platform that is not product-centric, but customer-centric — product-agnostic and geography-agnostic. The premise is simple: there will always be new products we cannot predict today, so the system itself must be adaptable.

That choice was not the fastest path. It was a big decision, a difficult one and it took longer up front. But it created consistency and control — principles that now apply directly to AI governance.

Governance is not a one-time decision; it is an ongoing discipline and a continuously evolving effort that must be built into the organization. At the same time, product and feature cycles are compressing rapidly.

Nowhere is that tension more visible than in fraud. It is easy to eliminate fraud entirely — you could decline every transaction and have zero fraud. But that is not a strategy. The real objective is minimizing friction while maximizing fraud capture.

The risk environment is also shifting quickly. Platforms that cannot respond dynamically to emerging threats will fall behind. Preparation requires agility, scalability and real-time intelligence.

This is where the next phase becomes critical. Agentic AI is not just about smarter models, it is about systems that can perceive, reason and act within defined guardrails, learning from outcomes over time.

But autonomy does not remove accountability. Responsible AI governance is non-negotiable. It requires transparency, consent and traceability in how data is used. And critically, the human role becomes more strategic — overseeing AI to ensure decisions remain fair, explainable and aligned with business outcomes.

The institutions that succeed will not be the ones that simply move fastest. They will be the ones that build the discipline, architecture and accountability to govern AI — because in payments, every decision is now real time, automated and consequential.

In a world where AI makes the decision, governance is what earns the right to make it.