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Know Your Customer, Know Your Agent

The New Casas de Cambio

Know Your Customer, Know Your Agent, part 2: the operator · October 7, 2026 · John Beckwith, Cooper Beckwith, LLC

Abstract

Between you and the person whose money moves there is now a platform that runs the agent: a frontier lab's assistant, a big tech wallet, a fintech, a data aggregator, or an agent sold through your core provider's marketplace. That platform is the operator. It identifies its own principals, aggregates thousands of them, and presents your institution with volume at machine speed. Wachovia paid $160 million in 2010 for treating $420 billion of casa de cambio traffic as if it came from customers it knew.

This paper applies the correspondent banking template to agent operators. The due diligence program the rule requires for foreign correspondent accounts transfers almost without edits. It sizes the volumes the networks project, shows how fraud models built on human behavior misfire in both directions, and lists the short contractual demands an institution can make of an operator: identify the agent, enforce the mandate, keep the logs outside the agent, test for prompt injection, and attest annually.

Know Your AgentAML and KYCAI risk

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