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Article April 30, 2026

AI accountability battle intensifies across financial services leadership

AI accountability battle intensifies across financial services leadership

Gerry Kounadis, Director of Group Data Privacy, Technology & ESG Compliance Advisory, National Bank of GreeceLinkedIn profile for Gerry Kounadis

As AI systems take on greater decision-making roles, financial institutions face mounting pressure to redefine accountability, governance, and risk frameworks. Gerry Kounadis warns that boards cannot delegate responsibility, even as regulators move to tre

As artificial intelligence systems evolve from analytical tools into active decision-makers, financial institutions are facing a fundamental shift in governance and accountability.

According to Gerry Kounadis, Director of Data Privacy, Tech and ESG Compliance Advisory at National Bank of Greece, the rise of agentic AI is forcing boards and executives to confront the limits of delegation.

Speaking ahead of CeFPro’s Vendor Risk Europe event in June, Kounadis said: “Ultimate accountability must remain with the board and senior management. “Fiduciary duties of oversight and judgment are non-delegable and cannot be transferred to an AI vendor.”

This position comes at a time when many organizations are increasingly reliant on third-party AI providers, often deploying proprietary systems that operate as opaque decision engines.

While vendors may carry legal responsibility for defects or failures under evolving regulatory frameworks, Kounadis emphasized that accountability for deployment decisions remains firmly with the institution.

“The company bears primary responsibility for deployment decisions, while the vendor carries significant responsibility for the model's integrity and compliance,” he said, noting that the boundaries between the two are likely to be tested as regulation matures.

The growing reliance on a single AI provider also introduces a new form of concentration risk, particularly in highly regulated sectors such as financial services. Kounadis warned that dependence on proprietary “black box” models can undermine transparency and resilience if not properly governed.

“If an organisation cannot explain, challenge, or replace a model, it should not rely on it for strategic decision-making,” he said, outlining a principle that is rapidly gaining traction among regulators.

To mitigate these risks, boards must implement robust oversight mechanisms, including independent validation of AI models, contractual rights to audit vendors, and clear documentation of decision outputs.

Just as critical is the ability to exit or substitute a provider if needed, ensuring that institutions are not locked into systems they cannot control.

The question of where to draw the line between decision support and decision replacement is becoming increasingly urgent. Under European corporate law, the distinction is not merely theoretical but carries legal implications.

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