Sebastien Rousseau

CATEGORY

Policy & resilience

DORA, EU AI Act, NIST standards, third-party risk — the supervisory pressure shaping technology decisions.

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Tags in this category

  • DORA — 40 articles

    Digital Operational Resilience Act — register of information, ICT third-party risk, threat-led penetration testing, and the operational resilience programme banks must run.

  • NIST — 4 articles

    NIST standards relevant to banking — FIPS 203/204, AI RMF, SP 800/1800 series — and the supervisory adoption patterns around them.

  • EU AI Act — 3 articles

    Implementation guidance, supervisory expectations, high-risk system classification, and the conformity-assessment burden the Act puts on banks.

  • Third-party risk — 1 article

    ICT third-party risk under DORA, EBA outsourcing guidelines, and the supervisory expectation around critical-vendor concentration.

Recent articles in Policy & resilience

INFRASTRUCTURE & CRYPTOGRAPHY

KyberLib and the Post-Quantum Banking Migration in 2026: From Standards to Code

KyberLib turns the post-quantum banking migration from policy paper into inspectable Rust — FIPS 203 ML-KEM key encapsulation, hybrid classical-plus-quantum handshakes, no_std compilation for HSMs, crypto-agile abstraction boundaries, and the DORA Article 5 governance evidence boards now need.

APPLIED AI

CloudCDN: An Open-Source Blueprint for the AI-Native Edge in 2026

CloudCDN is an open-source blueprint for the AI-native edge — a zero-trust MCP gateway with 42 tools, atomic Durable Objects rate limiting, WebAuthn passkeys, signed URLs, SLSA Level 3 provenance, and 3,185 tests at 100% coverage, mapped to DORA, BCBS 239, and Basel III.

APPLIED AI

The Wholesale Payments Index in 2026: ISO 20022, Tokenised Deposits, Real-Time Rails, and Cross-Border Settlement

An index framework for measuring wholesale-payments readiness in 2026: ISO 20022 structured-address compliance ahead of SWIFT's November 2026 milestone, tokenised-deposit settlement, BIS Project Agorá cross-border atomicity, real-time rail orchestration, and liquidity efficiency. Four percentages — structured-data completeness, rail-routing optimality, settlement-finality lag, and Agorá-corridor coverage — turn payment-operations posture into supervisory-ready evidence.

APPLIED AI

The Cloud Native Banking Index in 2026: DORA, Platform Engineering, Sovereign Cloud, and Operational Resilience

An engineering blueprint for cloud-native banking in DORA audit phase. Five platform-engineering primitives — Kubernetes paved roads, Backstage portal, GitOps via ArgoCD, Open Policy Agent admission, OpenTelemetry end-to-end — produce Article 8 register evidence at the speed of the pipeline. Tested exit-execution annually for CTPP-dependent CIFs against BIA-derived RTO targets. Sovereign-cloud options (AWS European Sovereign Cloud, Microsoft EU Data Boundary, Bleu, Thales / S3NS) addressed as engineering decisions, not branding.

APPLIED AI

The Quantum-Safe Banking Index in 2026: Post-Quantum Cryptography, QKD, Crypto-Agility, and Harvest-Now-Decrypt-Later Risk

An index framework for measuring quantum-safe banking readiness in 2026: cryptographic bill of materials, hybrid TLS deployment, NIST FIPS 203 / 204 / 205 migration progress, crypto-agility primitives, and harvest-now-decrypt-later exposure across long-lived confidential data. The Board-Level Quantum Scorecard defines four exact percentages — inventory completeness, HNDL exposure, NIST migration progress, crypto-agility readiness — that turn project statuses into supervisory-ready evidence.

APPLIED AI

The Agentic AI Index for Banks in 2026: Measuring Autonomy, Governance, Auditability, and Business Impact

An engineering blueprint for agentic AI in tier-1 banks: classify by permissions not intelligence, treat every production agent as an SR 11-7 / SS1/23 model from day one, and build the five-component control plane — OAuth-scoped service accounts, deterministic semantic routing, OPA policy gates, immutable WORM audit logs, and a tested kill switch — that turns autonomous workflows into auditable evidence.

APPLIED AI

Post-Quantum Payments Infrastructure: Why Banks May Replace Rather Than Retrofit Legacy Rails

Harvest-now-decrypt-later turns today's TLS-protected payment messages into tomorrow's decrypted exposure. ML-KEM and ML-DSA are an order of magnitude larger than the RSA and ECC keys legacy rails were sized for — retrofit triggers fragmentation, latency, and HSM exhaustion. The 2026 architectural decision is whether to patch or replace before the regulatory clock runs out.

APPLIED AI

Wholesale Digital Markets in the UK: Tokenised Gilts, Settlement, and the New Champion Role

The UK Wholesale Digital Markets Champion role makes tokenised gilts, DLT-based settlement, and digital wholesale finance a national competitiveness project. The 2026 strategic question for banks is design discipline — which tokenised assets sit on which platform, how settlement risk is evidenced, and how to defend the City's wholesale role against Singapore, Switzerland, and Frankfurt.