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Jane Fraser (Citi) Sets Limits on AI Agents: “We Need the Right Controls”

Jane Fraser, CEO Citi Group — Photo courtesy

Jane Fraser, Chair and CEO of Citi, put the spotlight on the risks posed by the advancement of artificial intelligence agents in the financial sector during the opening session of Sibos 2026, held this Monday in Miami. Her message was clear: before allowing these systems to move from providing information to autonomously executing actions, it will be necessary to guarantee their identity, authentication, and oversight.

Fraser illustrated the technology’s potential with an everyday example. “I don’t trust my husband to do the grocery shopping, so I can’t wait to have an agent that doesn’t just build a list for me, but actually does it for me,” she joked.

However, the leap between recommending and acting introduces much greater risks. Authentication, she stated, is one of the issues that “keeps us all up at night.” The challenge consists of being able to verify that an agent is truly acting on behalf of a person, and that both the bank and the other participants in a transaction can confirm its legitimacy. “Until then, I am confident I won’t have wild agents without the right controls in place,” she affirmed.

A Control Layer for Citi’s Agents

Fraser explained that Citi has already developed a specific mechanism to control the deployment of AI agents within the institution: a layer known as ARC. “You cannot create an agent without going through ARC,” she noted. This infrastructure concentrates the control framework and observability layer necessary to verify that agents do what they were designed to do, and that their activity can be monitored at all times.

The Citi CEO even anticipated a shift in the supervision model. If traditionally a manager might supervise nine employees, in an environment dominated by AI agents the ratio could invert: a single agent could be subjected to nine different oversight mechanisms, many of them managed in turn by other agents. “It is very early days in those controls, as we can all see,” Fraser acknowledged.

The IMF Focuses on Cyber Risk

The risks associated with artificial intelligence were also present in the remarks by Dan Katz, First Deputy Managing Director of the International Monetary Fund (IMF), who pointed out that there is a broad debate on whether increasingly powerful AI systems might eventually demand new regulatory responses.

Among the most immediate threats, Katz placed cyber risks “at the top of the list.” AI, he explained, is transforming this domain by accelerating the speed, frequency, and scale with which vulnerabilities can be detected and potentially exploited.

For public policy makers, the challenge will be creating an environment that allows innovation to be harnessed without compromising the integrity and stability of the financial system. Fraser agreed in identifying cybersecurity as one of the great challenges of this new technological era. “We have a tsunami of patches that need to be applied right now, and we have to be very responsible in achieving that,” she stated.

Innovating Without Breaking Trust

Citi’s CEO extended this need for control to the financial system’s broader technological transformation. “If you move fast and break things, we are failing in our mandate,” she asserted. Contrasting with the well-known tech axiom of moving fast even if errors occur, Fraser maintained that financial institutions must innovate rapidly without jeopardizing the trust upon which the system rests. “If we break trust, it is a huge problem for the macro, for the markets, for everywhere,” she warned.

As the velocity of money increases, she added, “resilience and trust go hand in hand.” Citi moves roughly six trillion dollars daily, and Fraser foresees transaction volumes rising significantly as artificial intelligence gains ground in the economy. Clients, furthermore, demand round-the-clock, instantaneous services that are also safe and reliable. Fraser cited Citi Token Services’ digital deposit solutions as an example, which enable money transfers via blockchain technology and integrate with clearing capabilities available 24 hours a day, seven days a week.

The next step, she noted, will be for other components of the financial infrastructure to move toward continuous availability as well, including central banks. Fraser summarized the equilibrium that, in her view, should guide this transformation: “Let’s do it safely, securely, and fast.”

30 Years, Five Cycles, and One Certainty: The Fed Is the Fed and Rules the Markets

| By Amaya Uriarte | 0 Comentarios

There are few economic decisions capable of simultaneously altering the price of money, currency values, credit costs, stock market behavior, bond markets, and international capital flows across the entire globe. One of them is a decision by the Federal Reserve. The Fed demonstrated this once again on September 16, when it raised its benchmark rate by 25 basis points to a range of 3.75% to 4.00%, in a unanimous decision by the Federal Open Market Committee. The reasoning was familiar: inflation remains elevated and the U.S. economy maintains a solid enough pace of activity to justify a more restrictive monetary policy.

However, this time there is something different. It is not merely an isolated hike; markets are beginning to price in that the movement may continue, and several signals point in that direction. For example, the Federal Reserve Bank of San Francisco noted in early September that financial markets were expecting the rate to reach approximately 4.25% by mid-2027, which would be equivalent to two or three additional 25-basis-point increases from current levels.

The Fed itself is somewhat more cautious: its September projection places the median rate at 4.1% at the close of both 2026 and 2027, although the distribution among officials shows considerable dispersion. The difference between both views is important, but even more important is history, because this is not the first time the Fed has embarked on a path of monetary tightening.

Over the last 30 years, at least five major episodes can be identified that allow us to observe what happens when the U.S. central bank decides that money should stop being so cheap:

1994–1995: The Greenspan Scare
1999–2000: The Fed Cools Down the Tech Party
2004–2006: Greenspan’s Measured Pace
2015–2018: Normalization After Near-Zero Money
2022–2023: The War Against Inflation

Five episodes, five distinct economic circumstances, and five different market responses. But with one common element: when the Fed moves rates in a sustained manner, virtually no major market remains indifferent.

1994: When the Fed Surprised the World, and Mexico Collapsed

The first of the major episodes of the period began in 1994. The U.S. economy was growing, and the Federal Reserve decided to preempt potential inflationary pressures. The result was one of the most aggressive tightening processes of the modern era up to that point. The federal funds rate went from around 3% at the beginning of 1994 to 6% in February 1995. Among the most remembered decisions was the 75-basis-point increase in November 1994; the problem was that markets were unprepared for the speed of the adjustment. As a consequence, U.S. bond yields surged sharply, causing a major correction in fixed-income markets. The impact was not confined to the United States either, as Mexico was particularly exposed.

The rising cost of money in the United States contributed to tightening financial conditions for emerging markets just as Mexico faced its own vulnerabilities: debt, external imbalances, and an exchange rate that would prove unsustainable. In December 1994, the peso crisis erupted. The Federal Reserve Bank of Dallas has noted that U.S. tightening delivered the final blow to a Mexican economy already exhibiting internal vulnerabilities. Between November 1994 and March 1995, the real exchange rate of the peso collapsed by more than 40%, while three-month Cetes rates had risen from around 10% in February 1994 to 14% in November. The episode left a primary lesson:

The Fed does not need to directly trigger a crisis to become part of it. It is enough for it to change the price of money in the United States for highly indebted countries, vulnerable currencies, and markets dependent on external financing to begin feeling the pressure.

1999–2000: Cold Water on the Tech Party

Five years later, the backdrop was completely different; the U.S. economy was enjoying the expansion associated with the technological revolution, the internet had transformed corporate expectations, and equity markets had entered a genuine frenzy. Then, the Fed raised rates again, with the federal funds rate going from 4.75% in mid-1999 to 6.5% in May 2000 after several consecutive hikes. The Nasdaq reached its historical peak of that era on March 10, 2000.

At that time, the largest companies on the Nasdaq were dominated by tech firms; six of the top 20 companies had not even recorded profits in the final quarter of 1999, according to a subsequent analysis by the Federal Reserve Bank of San Francisco. The Fed did not create the tech bubble nor was it the sole cause of its eventual burst. Extreme valuations, expectations around new technologies, and massive capital inflows played fundamental roles, but rising borrowing costs altered financial conditions.

Then a recurring feature of Fed cycles reappeared: when rates rise, the price investors are willing to pay for future growth changes, and tech companies were particularly sensitive to that shift. The epilogue of this Fed tightening brought a long correction for the Nasdaq and a subsequent economic recession in the United States.

2004–2006: The Measured Pace That Couldn’t Prevent the Storm

The next cycle is especially interesting because the Fed tried a different approach. After lowering the benchmark rate to just 1% in 2003 and keeping it there for an extended period, the central bank began a process of gradual increases in June 2004. There were 17 consecutive 25-basis-point hikes, pushing the rate from 1% to 5.25% by June 2006.

The Fed’s own language spoke of “measured” adjustments, but the economy had already accumulated significant imbalances, especially in the housing market and mortgage credit. In June 2006, when the Fed raised the rate to 5.25%, it acknowledged that growth was moderating and the housing market was cooling down, while warning that inflationary risks persisted. A year later, rate cuts began, and shortly after came the global financial crisis.

The link between the 2004–2006 hikes and the 2008 crisis must be handled with care: monetary tightening alone does not explain the crisis, as mortgage market dynamics, leverage, securitization, and risk management were decisive. But the cycle left a vital lesson: the effects of rate hikes do not necessarily show up the moment the Fed presses the button—they can take months or even years to manifest.

2015–2018: The End of the Near-Zero Money Era

The following experience was even more peculiar. After the 2008 financial crisis, the Fed slashed rates to near zero and kept them there for years. It was not until December 2015 that the normalization phase began. The first hike was 25 basis points, moving the target range to 0.25%–0.50%. Gradual increases followed in 2016, 2017, and 2018; by December 2018, the rate stood at 2.25%–2.50%—a policy clearly distinct from 1994.

The Fed was not trying to rein in an overheating economy or a tech bubble; it was attempting to return gradually to a more normal monetary policy after nearly a decade of extraordinary easing. But the market ultimately remembered who held the keys to money. Toward the end of 2018, concerns grew over global growth, trade tensions, and financial conditions. The Fed signaled it would be patient regarding further adjustments; consequently, the rate did not come close to 2000 or 2006 levels, yet the market still reacted. After years of near-zero rates, 25 basis points carried a very different significance for investors.

2022–2023: The Fed Brings Out the Heavy Artillery

If the previous four cycles had demonstrated the Fed’s power, the episode starting in 2022 recalled something even more fundamental: when inflation becomes the primary threat, the Federal Reserve can raise rates with extraordinary speed. In March 2022, the target range was 0.25%–0.50%, but by December of that year, it had reached 4.25%–4.50%. That was seven rate hikes in nine months, including four consecutive 75-basis-point increases between June and November. The rate continued upward in 2023 to reach 5.25%–5.50%, triggering global financial tightening. The U.S. dollar surged against numerous emerging currencies, sovereign yields rose, financing costs escalated, and investors sought shelter in U.S. assets.

The IMF had warned that accelerated Fed tightening could trigger capital outflows and currency depreciations in emerging markets. In July 2022, the institution noted that dollar strength was exacerbating inflationary pressures in other nations while capital was departing emerging markets. Once again, the Fed moved a U.S. rate, and once again, the impact crossed borders. Now, a story seen across at least the past three decades of financial globalization begins anew as we enter 2026.

The Fed has just raised its reference rate again to 3.75%–4.00%, but the context differs from 2022. Four years ago, the U.S. economy was emerging from the pandemic with inflation at multi-decade highs. Today, the economy continues to expand, productivity has strengthened, and corporate investment remains robust, though inflation stays above the 2% target. The Fed projects 2026 PCE inflation at 3.7% before gradually declining toward 2% by 2029. Meanwhile, markets are beginning to price in additional hikes.

The San Francisco Fed estimated in early September that markets were discounting a rate near 4.25% by mid-2027—equivalent to two or three additional 25-basis-point moves. That does not guarantee it will occur, but the Fed’s median forecast sits at 4.1% for late 2027, with a wide dispersion of scenarios among officials. For markets, the debate is already underway.

The Fed Changes a Rate; Markets Change Regimes

Here lies perhaps the main lesson of the past 30 years. There is no formula stating that every Fed hike triggers a stock market crash, a crisis, or a recession. In some episodes, equities continued rising during much of the cycle. In others, bonds suffered first. In still others, emerging currencies or speculative market segments took the hit. What does repeat is something else:

A rate hike changes the relative price of money, altering valuation rules for virtually every asset class. Rates impact credit costs, affecting consumption and investment; rates alter the relative appeal of bonds versus equities; and the spread between U.S. rates and the rest of the world influences capital flows, the dollar, and emerging currencies.

The Chicago Fed summarizes this transmission mechanism: changes in the federal funds rate propagate to other interest rates, the international value of the dollar, and asset prices that shape spending and investment decisions. That is why the Fed can make a decision in Washington and trigger moves in Mexico City, São Paulo, London, Tokyo, or Buenos Aires.

Five Cycles, Five Different Markets

Another takeaway is essential: the five episodes did not produce identical outcomes because the world the Fed confronted was different each time. In 1994, the key risk for emerging markets was external debt dependency; in 2000, tech exuberance; in 2006, housing and financial leverage; in 2018, unwinding a decade of near-zero rates; in 2022, global inflation forcing central banks off emergency policies.

Today’s landscape introduces new variables: massive fiscal deficits, extraordinary funding needs, huge AI investments, geopolitical shifts, energy, tariffs, and a U.S. economy showing an unusual mix of growth and persistent inflationary pressure. The sixth episode will not necessarily mirror any of the previous five, but the underlying mechanics endure. When the central bank issuing the primary global reserve currency alters the price of money, the rest of the planet must adjust.

The Certainty

Thirty years provide enough perspective to distinguish between a coincidence and a pattern: not every Fed rate-hike cycle ended in crisis; not all triggered bear markets; not all hit emerging markets equally. But all of them forced markets to recalculate the price of money and the value of assets.

The core question should not just be whether the Fed will raise rates another 25 or 50 basis points, but what happens when investors, after adapting to specific financial conditions, realize the rate regime is shifting once again. The past 30 years offer five different answers, none suggesting a Fed rate hike is a minor event. Amid few certainties in financial markets, one stands firm: when the Fed changes course, the markets listen. Traders capture this reality in a phrase repeated through every cycle: The Fed is the Fed.

AllianceBernstein appoints Onur Erzan as President and Chief Executive Officer

| By Amaya Uriarte | 0 Comentarios

Photo courtesyOnur Erzan, President and Chief Executive Officer of AllianceBernstein

AllianceBernstein Holding L.P. and AllianceBernstein L.P. have announced that Onur Erzan, President, has been appointed President and Chief Executive Officer of AB, effective April 1, 2027. According to the firm, he will succeed Seth Bernstein, who will retire on March 31, 2027, after nearly a decade at the helm of the firm. Bernstein will continue to serve on AB’s Board of Directors.

“Onur is an exceptional leader with broad experience in asset management and insurance. Since joining AB, he has helped define the firm’s strategy, expand its capabilities, and position the business for sustained growth. At the same time, this transition provides an opportunity to recognize Seth’s extraordinary contributions over the past decade. He has led AB through a period of significant growth and helped strengthen the partnership between Equitable and AB at a decisive moment for our company. I thank Seth for his leadership and am pleased that he will continue to serve on AB’s Board of Directors,” said Mark Pearson, CEO of Equitable Holdings and member of AB’s Board of Directors.

During his tenure as CEO, Bernstein supervised a period of deep transformation at AB. Under his leadership, the firm has continued to evolve beyond its traditional roots in active public markets asset management to become a leading, diversified global investment manager with scaled businesses across public markets, private alternative assets, private wealth management, insurance asset management, and retirement solutions. Furthermore, Bernstein drove structural improvements in the firm’s profitability by relocating AB’s headquarters to Nashville, establishing and developing AB India, and transforming Bernstein Research into a joint venture with Société Générale. Bernstein also promoted initiatives to reinforce the firm’s culture, broaden its global distribution platform, and open new avenues of profitable growth, with AB’s assets under management nearly doubling to top $919 billion as of August 31, 2026.

“It has been the privilege of my life to lead this extraordinary firm,” said Bernstein. “Over the past decade, we have expanded our reach, strengthened our distribution, and developed durable growth engines that enable us to better serve our clients around the world. I am thrilled that Onur is taking the reins to lead AB into this next phase, as he has played a key role in our strategy and led much of its execution. He embodies many of the values that I believe distinguish AB’s success: putting our clients’ interests first, applying a rigorous intellectual process to the decisions we make, and demanding excellence in everything we do. I have full confidence in Onur’s leadership and in the opportunities ahead for this firm.”

Onur assumed the role of President in January 2026 and oversees AB’s Private Wealth Management, Global Private Alternatives, and Global Asset Management Distribution businesses, as well as the firm’s Strategy and Corporate Development functions. He has served on the Executive Committee of Equitable Holdings since 2021 and, following the closing of the previously announced merger between Equitable Holdings and Corebridge Financial, will join the company’s executive leadership team led by CEO Marc Costantini.

“It is an honor to lead AB at such a decisive moment in our history. For nearly six decades, AB has been distinguished by investment excellence, intellectual rigor, and a collaborative culture relentlessly focused on clients. In an environment where the wealth and asset management industry is undergoing rapid transformation—with clients seeking closer relationships, broader capabilities, and more integrated solutions—AB is uniquely positioned to deliver the insight, capabilities, and collaboration they need to achieve differentiated outcomes. I look forward with excitement to writing the next chapter of AB’s history alongside our talented and dedicated colleagues around the world,” stated Erzan.

Since joining AB in 2021, Erzan has helped define and execute the firm’s global asset management distribution strategy, in addition to playing a key role in AB’s expansion into new business areas, including the launch of its active ETF offering, the creation of an integrated insurance asset management division, and the expansion of AB’s private credit and broader retirement income generation solutions. As head of Bernstein Private Wealth Management, Erzan significantly strengthened the firm’s capabilities aimed at ultra-high-net-worth clients, global families, and family offices through tailored solutions. Likewise, he played a fundamental role in strengthening Bernstein’s external partnerships with international banking institutions and custodians, while expanding the reach of its wealth management business and client coverage capabilities.

Prior to joining AB, Erzan spent 20 years at McKinsey & Company, where he most recently served as Senior Partner and co-led the Global Wealth & Asset Management practice. In that role, he advised prominent global asset managers, wealth management firms, insurers, and retirement-focused financial institutions on M&A operations, transformation processes, and long-term growth and value creation initiatives. Beyond his professional responsibilities, he maintains a strong commitment to the community and has served on the boards of directors of Graham Windham and Turkish Philanthropy Funds. He holds a bachelor’s degree in Business Administration from Middle East Technical University in Ankara, Turkey, and an MBA from Columbia Business School.

Insigneo Strengthens Its Presence in Puerto Rico With a New Managing Director

| By Amaya Uriarte | 0 Comentarios

Photo courtesyJavier Estremera Muñiz, Managing Director at Insigneo

The wealth management firm Insigneo is hiring in the region, swelling its operation with two hires in Puerto Rico aimed at asserting the company’s position in the U.S. territory in the Caribbean. This includes the arrival of a new Managing Director, Javier Estremera Muñiz, who brings two decades of experience in the financial services industry with him.

According to a press release highlighted by the firm, the professional has developed a career focused on advising individuals and families, with personalized guidance and long-term relationships. This trajectory has seen Estremera advise his clients on wealth preservation, retirement planning, education funding, and legacy strategies, among others.

The executive spent the bulk of his career at Merrill Lynch Wealth Management, according to his LinkedIn profile, where he served as Senior Financial Advisor and First Vice President at the U.S. firm.

“I am excited to join Insigneo and become part of a platform that shares my commitment to personalized service and long-term client relationships,” Estremera commented in the press release. “I look forward to continuing to help individuals and families achieve their financial goals, leveraging the resources and capabilities available across the Insigneo network,” he added.

Estremera’s arrival is accompanied by the onboarding of Yomaris Negrón, his Client Service Associate. This further reinforces the wealth management firm’s team in Puerto Rico. In this country, they added, their focus remains on continuing to invest and attract experienced investment professionals.

“Puerto Rico remains an important market for Insigneo, and Javier’s addition brings valuable experience and a strong client-first perspective to the team,” emphasized Alfredo J. Maldonado, Managing Director & Market Head for the firm’s Northeast region, celebrating Estremera’s arrival.

How Are Cryptocurrency ETFs And In Which Markets Do They Exist?

| By Amaya Uriarte | 0 Comentarios

Cryptocurrency ETFs allow gaining exposure to digital assets such as bitcoin or ether without the need to buy and custody them directly. They are traded on the stock exchange through a financial intermediary, similarly to other exchange-traded products.

However, not all vehicles that the market calls “cryptocurrency ETFs” legally have the structure of a traditional exchange-traded fund. Depending on the country, they can take the form of an ETF, ETP, ETN, or trust. Therefore, in addition to knowing the asset to which they offer exposure, it is important to review the legal structure of each product.

How They Work

There are two main structures. Spot or cash products directly hold the underlying cryptocurrency in custody and seek to track its price, minus fees and other expenses. Futures-based products, on the other hand, invest in derivative contracts on the cryptocurrency. In this case, the performance may differ from the behavior of the asset due to, among other factors, the cost of rolling over the contracts.

There are also products that group several cryptocurrencies and others with leveraged or inverse exposure. The latter have more complex characteristics and are generally aimed at short-term strategies. The investor must distinguish between direct exposure to the asset, exposure through derivatives, and exposure to a combination of assets.

Why They Interest Investors

The main operational advantage is access. The investor does not need to manage private keys or directly use a cryptocurrency exchange platform. The custody of the asset, where applicable, is handled by specialized entities.

In addition, these instruments can be incorporated into a traditional portfolio and traded through existing investment accounts. For managers, advisors, and institutional investors, this makes it easier to integrate exposure to digital assets into familiar investment structures. Regulatory, tax, and operational conditions, however, depend on each market. Nevertheless, transferring custody to a specialized entity does not eliminate the risk: it delegates it. The solidity of the custodian, issuer, and product providers remains relevant.

Where They Exist

In the United States, spot products linked to bitcoin and ether are traded, in addition to futures-based vehicles. Many are legally structured as ETPs or trusts, although they are commonly referred to as ETFs.

Canada was one of the first countries to authorize spot cryptocurrency ETFs. In Europe, a large portion of the offering takes the form of ETPs or ETNs and trades on markets such as Xetra, Euronext, or SIX Swiss Exchange. They are not usually traditional UCITS ETFs, partly due to the diversification rules applicable to these funds. ETNs, moreover, can incorporate credit risk from the issuer.

In Asia-Pacific, Hong Kong and Australia have spot ETFs. In Latin America, Brazil has a broad offering of ETFs linked to different crypto assets. Chile also has a bitcoin ETF fund, while in Argentina certain foreign ETFs can be accessed locally through CEDEARs.

The specific availability for each investor depends on their country, their intermediary, and the applicable marketing regulations.

What the Investor Should Analyze

The traded format simplifies access, but it does not eliminate the volatility of the cryptocurrency it replicates. Before investing, it is advisable to review what the product replicates, whether it holds cryptocurrencies or uses derivatives, who performs the custody, what its fee is, and what liquidity it has. It is also necessary to consider the tax and regulatory treatment of each jurisdiction.

In short, a cryptocurrency ETF or ETP is, above all, an access vehicle. Its operation and its risks depend on the specific structure of the product and the market in which it is listed.

Johnson’s “Guns and Butter” Analogy

| By Amaya Uriarte | 0 Comentarios

The rate hike and Kevin Warsh’s press conference transmitted a certain sense of calm to equity investors, who now do not see it as likely as in 2022 that the Fed will fall behind the curve. However, the yield on 10- and 30-year government bonds has continued to be volatile and trend upward.

Uncertainty regarding the conflict in Iran and how far it could push oil prices continues to weigh on investor sentiment, encouraging some well-known Wall Street strategists to advocate the similarities between the current cycle and what happened in the early 1960s, Lyndon B. Johnson’s “guns and butter” era.

The analogy with Lyndon Johnson, who simultaneously funded Vietnam and the “Great Society,” rhymes with the current moment. But it rhymes with 1965–68, not the early sixties: a late-cycle economy, at full employment, receiving a fiscal boost when there is no longer any slack.

How does it compare to the current picture? On September 16, the Fed raised rates by 25 bps, to 3.75%–4.00%, the first hike in more than three years. Furthermore, it raised its core PCE forecast for 2026 to 3.4%. It did so even though the Administration actively pressured it to hold back. On the fiscal front, there is an added request of $1.5 trillion for defense, and the CBO projects a deficit of 5.8% of GDP and debt at 101%. The 10-year closed the week of the rate hike at 5%.

What are the similarities with “guns and butter”? Today, as in 1965, an armed conflict and an expansion of public spending coincide with full employment (procyclical fiscal spending, quite heterodox in a historical context): unemployment below 4% then, 4.1% now. The tug-of-war between the White House and the Fed is also repeating itself. In December 1965, Johnson reprimanded Martin, then head of the Fed, at his ranch for raising the discount rate; today the tension is between Trump and Warsh. In the stock market, the concentration in megacaps linked to AI recalls the genesis of the Nifty Fifty, although with much less striking valuations among its main representatives.

But there are also differences; the fiscal aspect plays against us. In 1965, debt hovered around 40% of GDP and was falling. Johnson’s deficit barely reached 3% in 1968. Today, debt is two and a half times higher and growing, so the risk is greater than back then.

Wages play in our favor. What made the inflation of the sixties chronic was the wage spiral, with strong unions and COLA clauses (cost-of-living adjustment clauses) applied to social security payments. Today wages are growing at 3.1% year-on-year, and the post-pandemic trend is clearly downward. Current inflation is largely supply-driven, due to energy and tariffs, and without indexation it can dissipate; this is made clear, for example, by the Federal Reserve Bank of San Francisco.

Finally, there are no similarities regarding the monetary regime either. Bretton Woods and financial repression allowed the adjustment to be postponed until August 1971. Today, with a floating exchange rate and “bond vigilantes” on alert in recent months, the adjustment arrives via the term premium, in a faster and more volatile manner.

And although Warsh acts today like Martin in 1965–66, his speech leaves no doubt regarding the objective of containing and controlling inflation, and thus recovering credibility and confidence in the Federal Reserve. The problem back then was not the rate hike, but what came after: the Fed overestimated the Government’s capacity to raise taxes, and its rate cuts in 1967–68 were miscalculations with the economy already at full employment. The key question is whether the Fed will maintain its focus after the midterms in November; if Trump ultimately loses control of both houses, pressure in Iran could increase significantly.

Scenario Analysis

Trying to add some color, our scenario analysis (with subjective probabilities) would look like this:

1.- “1966 Analogy” (45%). The Fed stands firm and there is a mid-cycle slowdown, similar to the roughly 20% drop in the S&P that year, followed by a recovery.

2.- “1967–68 Analogy” (25%). The Fed yields after the “midterms” and inflation gets stuck above 3%. The term premium rises steadily and a prolonged regime of poor real returns opens up for 60/40 portfolios, like the one that followed between 1966 and 1982.

3.- “AI Productivity” (30%). Capex expands capacity and absorbs the fiscal boost, as in the late nineties.

Implications for Asset Classes

And how does this outlook affect the major asset classes?

Fixed income: Conservative stance on duration relative to the index in US nominals, with a steepening bias on the curve and some protection through inflation-linked bonds. With the 10-year around 5%, we are approaching an interesting area, but the risk of higher oil prices and a more dynamic labor market will weigh in the short term.

Real assets: Gold is the most asymmetric hedge against a complacent Fed, as demonstrated in the seventies. It can be complemented with positions in energy and commodities.

Equities: Concentration in quality at high multiples was paid for dearly in 1973–74 (Nifty Fifty bubble). However, in a context of uncertainty like today’s, with tech companies putting their balance sheets on the line, quality is proving to act as a haven. We are entering a period in which analysts have historically revised their earnings growth projections downward; according to the BofA manager survey, a certain complacency is perceived regarding the evolution of crude oil prices (42% of respondents expect the barrel to range between 70 and 80 dollars at year-end), which is evident in their levels of optimism; finally, retail margin purchases, in an area of excessive expansion (+37% year-on-year), reinforce the reading of short-term fragility.

The stock market rise since the rate hike meets the historical profile analyzed. The historical median is −3% at one and three months, with recovery from the fifth month. But the most similar cycle, that of March 2022, driven by supply inflation, was the only negative one at twelve months. With six observations, it is a directional reference.

Credit and dollar: In credit, short maturities with an emphasis on issuer quality. In the dollar, the rate differential supports it in the short term, but these regimes ended up depreciating it, as in 1971. That suggests flexible hedging ratios.

Three signals to watch that would bring us closer to the adverse scenario: a Fed pause or cut with core PCE above 3%, wages growing above 4%, and a lack of consensus within the Fed, with “dissenters” supporting cuts in the FOMC after November.

AIS Celebrates Ten Years with a Broader Platform and a Focus on Technology

| By Amaya Uriarte | 0 Comentarios

Photo courtesyIn the image, on the left is Samir Lakkis, Founder and Director of Sales at AIS Group, and on the right is Erik Schachter, Chief Investment Officer at AIS

This marks the tenth anniversary of the launch of AIS Financial Group, and the boutique firm specializing in investment solutions celebrated it at its annual meeting under the slogan “A decade of trust.” Over the past decade, the company has grown from building its business around structured products to developing a financial platform active in securitization, funds, and fixed income, with an expanding international presence.

This evolution has also been accompanied by a greater commitment to technology, which AIS considers key to automating processes, expanding its service capacity, and scaling the business without sacrificing the level of customer service that has characterized the firm since its inception. Currently, the company offers access to multiple issuers, structuring, and execution across various asset classes, backed by an extensive network of providers.

Samir Lakkis, Founder and Director of Sales, opened the event by reviewing the transformation experienced by AIS over its ten-year history. He stated that AIS maintains its independence while having expanded both its platform, geographic reach, and provider network. Among the main milestones of this evolution, he highlighted the opening of an office in Miami and the increase in the number of providers in what he described as a record-breaking 2025, with more than 35 issuers.

New business lines have been added to this activity. Securitization has become one of the fastest-growing areas, allowing different types of assets or investment strategies to be transformed into tradable securities. The fund business has also gained greater relevance, both through the launch of proprietary strategies and through fund distribution and collaboration with external managers. Added to this is its fixed income activity, offering tailored execution solutions across the United States, Europe, and emerging markets.

Technology has become another pillar of this expansion. AIS has an in-house technology department developing internal and client-facing tools, including Phoenix and Akoura. “Technology allows us to automate more processes, improve the service we offer to clients, and, above all, scale the business much faster without losing the quality of service that has always been fundamental for AIS,” Lakkis explained.

Thus, the company has evolved from a model focused primarily on structured products to becoming a financial platform with a broader array of activities, maintaining its independence as one of the key elements of continuity during its first decade.

Securitization: A Vast Universe of Instruments Across Diverse Asset Classes

Baptiste Saliva and Clément Rudi, Securitization Solutions Directors, alongside Mario Abi Karam, Relationship Manager, delved into securitization solutions and AIS’s ability to turn diverse assets and investment strategies into tradable instruments. Since it began operating in early 2022, the platform has securitized over $1 billion in assets, roughly half of which correspond to unlisted underlyings. To tailor structures to the needs of each transaction, AIS also works with more than 30 institutional counterparties.

Mario Abi Karam explained that in recent years, the company has structured positions in real estate projects, pre-IPO companies like OpenAI, physical gold, and third-party managed equity strategies, turning them into tradable, bankable securities. The goal is to facilitate access and distribution for investments that, due to their complexity, private nature, or access barriers, might present greater obstacles for investors.

“In essence, investment managers arrive with ideas that may be complex, private, or difficult to access or distribute, and we make them bankable,” Abi Karam summarized.

The process begins with the asset or strategy provided by the manager—ranging from a loan, fund, or portfolio to real estate—and continues with the issuance of a specific vehicle for that mandate, which investors can subscribe to directly from their existing bank accounts.

The solution can be applied to a wide range of asset classes, from equities, derivatives, bonds, and commodities to private markets, private equity, real estate, structured products, or digital assets. AIS maintains vehicles in the Cayman Islands, Luxembourg, and Guernsey, with the choice depending on manager preferences, investor profiles, and tax considerations. The company also manages the infrastructure associated with the product, including documentation, subscriptions and redemptions, bank and custody accounts, and net asset value (NAV) calculations.

“In short, if you can describe a strategy, we can make it bankable,” Abi Karam emphasized, summarizing the platform’s value proposition.

Baptiste Saliva later focused on the flexibility of the infrastructure. AIS can adapt its structures to different types of assets and strategies, and in recent months, it has developed new processes powered by artificial intelligence. As he explained, these tools are helping accelerate the structuring and issuance process, allowing a project to typically launch in about two weeks, even for complex or illiquid operations.

Clément Rudi addressed the operational structure and the various participants involved throughout the lifecycle of the product. “There are many actors involved in this framework to ensure it is compliant, secure, and efficient,” he noted. AIS coordinates the capabilities of its legal, tax, compliance, and marketing teams, while the administrator performs the necessary checks on the certificate prior to issuance and throughout its lifespan.

The paying agent handles payments and facilitates the secondary market; the broker enables the manager to execute the strategy; and the distributor subsequently channels the product to qualified investors. Within this setup, “our role is to provide investment managers with the best tool and the best structure to implement the strategy, and you only have to implement it correctly according to the term sheet,” Rudi explained.

The frequency of NAV calculations ultimately depends on the underlying assets and can range from daily to quarterly, based on liquidity and the valuation frequency of the assets themselves.

Investment Ideas

Erik Schachter, CIO of the company, focused his presentation on AIS’s market outlook and, in particular, the importance the firm places on momentum when designing investment ideas. Schachter explained that AIS seeks to offer diversified proposals across sectors such as consumer, technology, financials, communications, and energy, tailoring opportunities to prevailing market conditions.

Regarding structures, around 60% of the proposed ideas are autocallables, though the firm also works with different participation mechanisms and payoff structures to diversify the solutions available to clients. According to data presented, 86% of AIS’s ideas in 2025 delivered positive returns, compared to 14% with negative returns.

Schachter stressed that analyzing an opportunity goes beyond identifying the attractiveness of a specific sector; it also incorporates momentum dynamics. “When we think of an idea, we think about the sector thesis, but it is also important for us to think about momentum,” he stated.

The reason, he explained, is that shifts in volatility can substantially alter the terms of an issuance. “It’s good to trade when the VIX is high, because you get a better coupon and better strikes.” In this way, two notes with seemingly identical parameters can yield different coupons depending on the market timing of their structuring. Using an example provided by Schachter, a VIX of 30 could yield a 12% coupon, whereas with a VIX of 20, the coupon dropped to 9%.

The manager cited a recent proposal tied to a DRAM memory ETF as a case in point. AIS launched the idea on August 5 with a 50% barrier and a 32% coupon. Two weeks later, the coupon had fallen to 22%—a ten percentage point difference that, according to Schachter, illustrates the significance of market timing when structuring these types of products.

Latin American Wealth Crosses Borders and Obtains a Global Passport

| By Amaya Uriarte | 0 Comentarios

Latin American wealth is no longer content to remain where it was created; today, the region’s high-net-worth individuals are expanding their investment horizons and making international diversification an increasingly important piece of their strategy. This phenomenon does not necessarily mean capital is fleeing Latin America, but it does mean a growing proportion of wealth management decisions are being made with a view beyond its borders.

Recent data from two of the world’s largest banks specializing in high net worth illustrate the magnitude of this shift. Citi’s Global Family Office Report 2026, based on responses from 351 family offices across 41 countries, identifies an increasing internationalization among families, greater sophistication in risk management, and a renewed interest in public equity markets, particularly in developed regions. Nearly 90% of participants reported positive portfolio performance year-to-date in 2026, while 41% maintain target annual returns of between 7% and 10%.

When looking specifically at Latin America, an even more telling picture emerges. UBS’s Global Family Office Report 2026 found that Latin American family offices currently have 60% of their portfolios invested in North America, compared to just 23% within Latin America itself. Another 11% is allocated to Western Europe, with the remainder distributed across Asia-Pacific, China, and other regions.

The picture is striking: for every dollar Latin American family offices keep invested within the region, they allocate roughly $2.60 to North America. And this does not appear to be a static picture.

UBS notes that 61% of Latin American family offices plan to make strategic asset allocation changes during 2026. Among their top investment themes, artificial intelligence leads with 77% preference, followed by infrastructure at 55%, and energy and resources at 45%.

This shift also bears a specific characteristic: Latin American high-net-worth individuals are not abandoning traditional assets to seek refuge exclusively in alternative investments. On the contrary, the regional portfolio shown by UBS maintains 66% in traditional asset classes and 34% in alternatives. Equities account for 32%, fixed income 29%, and cash 5%; on the alternative side, private equity accounts for 16%, followed by hedge funds, private debt, and other assets.

The transformation, therefore, is not simply about seeking more sophisticated assets. It runs deeper: combining liquidity, public markets, private investments, and international exposure within a wealth structure that is increasingly less dependent on its country of origin.

North America Becomes the Core Platform

The concentration in North America is not exclusive to Latin America. For U.S. family offices, the “home bias” is even greater: 88% of their portfolios are invested in North America, according to UBS.

The difference is that while a U.S. family office can find a vast array of stocks, bonds, private companies, infrastructure, and other assets within its home market, a Latin American family office operates from a different reality.

For a family whose core operating company, real estate holdings, or historical business is in Mexico, Brazil, Colombia, Argentina, or Chile, investing internationally offers a way to reduce the geographic concentration inherent in their business assets—a mindset shift also being accelerated by younger generations.

An analysis published this year by the CFA Institute highlights that Latin American family offices are evolving from vehicles primarily focused on wealth preservation into broader wealth strategy platforms. Next-generation family members are seeking diversification, private markets, and better risk-adjusted returns beyond traditional family businesses.

The shift can be summarized in a question becoming increasingly relevant among leading families: if the family business already represents a massive concentration of risk, why should the liquid financial portfolio be concentrated in the same country, currency, or sector?

The CFA Institute highlights an illustrative explanation from Mauricio Santos, Director of Investment Portfolios at GBM, who notes that when a family’s core business can no longer grow at a return on capital higher than what a diversified portfolio offers, attention begins shifting toward professional management of financial assets.

This marks a major evolution: while the first generation built the company, the next generation is focused on building wealth around the company.

The New Map of Wealth

This mindset helps explain why the United States occupies such a central position. Latin American investment in North America should not be interpreted solely as a bet on Wall Street. It also encompasses real estate, private equity, infrastructure, private debt, investment funds, technology companies, and other assets forming part of a much deeper financial ecosystem.

For family offices, internationalization entails far more than picking stocks or funds. Citi notes that 38% of surveyed families expect their degree of internationalization to increase over the next five years. In many cases, family assets, businesses, and members are already spread across multiple jurisdictions, increasing tax, regulatory, legal, and structural complexity.

In other words, the family office is moving beyond managing mere capital to managing an increasingly complex wealth geography. Here lies a significant opportunity for the U.S. offshore financial ecosystem.

Financial centers like Miami and New York are not competing solely to capture Latin American assets. They offer the banking, legal, tax, investment, and governance infrastructure required by families whose economic interests span multiple countries.

It is no coincidence that the CFA Institute identifies political volatility, interest rate shifts, and domestic market confidence as factors continuing to drive offshore allocation decisions among high-net-worth families in Brazil, Mexico, Argentina, and Colombia.

Furthermore, another element reframes the traditional narrative around family offices. After years in which private investments seemed to become the ultimate status symbol of wealth sophistication, Citi observes a renewed appetite for public markets.

Nearly half of the family offices surveyed by the bank increased their exposure to equities during 2026, making public markets the primary destination for new capital. Developed market equities, in particular, are the top asset class preferred for future net allocations.

For Latin American investors, this trend is especially notable. UBS data shows that 32% of their portfolios are currently in equities, with 24% specifically allocated to developed markets versus 9% in emerging market equities.

In short, diversification does not necessarily mean seeking exotic markets; to a large extent, it means stepping outside the home market to enter the world’s deepest and most liquid financial markets.

However, it is not all Wall Street. The growing North American footprint does not mean Latin American family offices are putting all their eggs in the U.S. basket. The same UBS report shows regional families maintain substantial geographic diversification: alongside the 60% in North America, they hold 23% in Latin America and 11% in Western Europe.

Valid reasons remain to keep capital in the region; exposure to energy, resources, infrastructure, and other real assets aligns with Latin America’s underlying economic structure. Indeed, UBS identifies energy and resources as one of the top three investment themes for regional family offices.

The strategy, therefore, is less about abandoning Latin America than preventing wealth from depending exclusively on it—that distinction is fundamental.

Artificial Intelligence Is Also Reshaping the Family Office

The transformation extends beyond where capital is deployed to how it is managed. Citi found that family offices are transitioning from experimenting with artificial intelligence to applying it across investment analysis, data management, reporting, process automation, and decision support. The immediate goal is not replacing investment managers, but driving productivity and enhancing core workflows like due diligence.

In Latin America, AI stands out as the single top investment theme identified by UBS, selected by 77% of respondents—outranking infrastructure and energy. This is revealing: it shows the new generation of Latin American family offices is attempting to solve two challenges simultaneously—diversifying wealth and professionalizing the institution that manages it.

The CFA Institute highlights this precise evolution: high-net-worth and ultra-high-net-worth clients possess greater financial literacy today and demand institutional setups where investment, tax, and legal professionals work in synergy, rather than relying on a single personal relationship with an advisor.

The Paradox: Higher Financial Sophistication, But Unresolved Succession

Perhaps the most intriguing aspect of this transformation lies in its paradox. While family offices grow more institutional, sophisticated, and global, wealth transition remains one of their greatest vulnerabilities.

Citi notes that approximately one-third of respondents expect a leadership transition within the family, the family office, or the family business over the next five years. Obstacles include unclear succession plans, inadequate preparation of future leaders, and a lack of alignment regarding long-term vision.

UBS reports a similar situation globally: only 35% of family offices have a defined succession plan for the family office itself, and just 27% have a structured process to prepare heirs. This data takes on added weight in Latin America.

The CFA Institute points out that much of the region’s wealth remains concentrated in the first and second generations. However, successors are already demonstrating a different relationship with money and risk.

They do not necessarily want to sell the family business or break with its legacy; rather, they want options. That can mean investing in international public markets, entering private equity or venture capital, acquiring real estate abroad, or constructing wealth structures that separate core business operational risk from family financial capital.

Succession, therefore, is not merely deciding who will inherit the business. It is deciding what type of wealth architecture the next generation will inherit.

The conclusion emerging from these studies is that the Latin American family office is entering a new era. The family enterprise may remain rooted in Mexico, Brazil, Colombia, or Argentina, the family may continue to reside in the region, and the core business may remain the primary source of wealth creation.

However, financial wealth now operates across a different geography. Portions may reside in U.S. equities, international funds, private equity, foreign real estate, infrastructure, and liquid cash instruments. Family members may study or live in different countries, and legal structures may span multiple jurisdictions.

In this environment, wealth ceases to carry a single financial nationality. UBS data summarizes it decisively: 60% of Latin American family office assets are deployed in North America, while 23% remains in the home region.

Citi, from another vantage point, projects that internationalization will continue to expand and cross-border complexity will become a structural hallmark of wealth management. That may ultimately represent the most significant transformation of all.

Latin America’s largest wealth holders are not necessarily leaving Latin America, but they are ceasing to rely exclusively on it.

How to Obtain Predictable Equity Returns with WisdomTree

| By Amaya Uriarte | 0 Comentarios

Photo courtesyTom May, Global CIO, Outcome and Derivative Strategies at WisdomTree.

Attendees at the second edition of the Funds Society Leaders Summit, in collaboration with CFA Society Spain, were able to learn a bit more about defined return investing through WisdomTree’s analysis, presented by Tom May, Global CIO, Outcome and Derivative Strategies at the firm.

In his presentation, May recalled that equity securities generate long-term returns, but these can vary considerably over time. Currently, for example, “European equities have a positive expected return, but exhibit severe drawdown events and fat tails.”

In this scenario, defined return investments—known as autocallables—increase the probability of achieving a specific return target. These types of products “harness the spread between equity forward and realized returns (ERP), as well as the persistent premium of implied volatility over realized volatility (VRP), to deliver higher and consistent yields,” May assures.

Ultimately, he poses the question of why settle for uncertainty when an investor can define their return and focus on achieving a defined yield in the most likely scenarios to maximize the investment.

WisdomTree’s defined return strategies feature a diversified portfolio of autocallable securities. But how does an autocallable security work? It is a structured investment product whose maturity and payouts depend on the performance of the underlying asset.

In short, autocallables allow for greater visibility regarding returns and a more probable path. Historically, forecasts and actual results have aligned, as seen when analyzing the real and projected performance of a portfolio of autocallable products historically managed by the WisdomTree team.

Why consider WisdomTree’s defined return autocallable strategies? May’s presentation highlights several reasons:

1.- Defined positive return in pre-established markets: Autocallables are designed to offer a positive return over their lifespan, unless the market suffers a significant drop and remains at those levels for an extended period.

2.- Higher probability of achieving expected outcomes: A diversified portfolio of autocallable securities can limit return variance within a target distribution range, increasing the probability of reaching that target.

3.- A more predictable investment process: A diversified portfolio of autocallable securities can capture long-term equity risk premiums while reducing the dispersion of returns that equity investors would otherwise face.

With its WisdomTree Defined Return Autocallable Strategies fund, the investor gains access to an equity-linked return, with defined outcomes and daily liquidity, through a product that actively manages a diversified portfolio of autocallable products and collateral, continuously optimizing maturities, thresholds, index pairs, and collateral. The product’s active approach adapts to market conditions, backed by 13 years of experience in these types of products.

Compliance Costs Transform Competition in the Offshore Market

| By Amaya Uriarte | 0 Comentarios

The US offshore business faces a paradox; on one hand, demands for transparency, anti-money laundering, and management of international clients elevate the complexity and cost of the financial business. On the other hand, authorities have begun to review certain obligations under the argument of reducing regulatory burdens and favoring competitiveness. Thus, while large banks can spread their costs among thousands of clients, small firms face a decisive question: how much wealth do they need to manage for compliance to be profitable? The US offshore business faces a paradox.

For private banks, asset managers, trust companies, and family offices serving international investors, the result is not necessarily a reduction in complexity. In many cases, compliance has become a permanent business function: it requires specialized personnel, technological systems, internal controls, and the capacity to respond to regulatory changes. The question is whether that cost structure is modifying competition; in a market where revenues depend on assets under management, an institution managing billions of dollars can distribute its compliance expenses across a broad base of clients and assets. A small firm, on the other hand, can face much of the same obligations with a much smaller scale.

The above does not mean that the large players are automatically winning, nor that the small ones are doomed to disappear. But it does pose a relevant hypothesis for the industry: regulation can become a barrier to entry and scale, an increasingly important competitive advantage.

The price of knowing the client

One of the main sources of costs is in customer due diligence, known in the industry as KYC, for its acronym in English: Know Your Customer. For a financial institution serving international wealth, opening an account can imply much more than verifying an identity. It must understand who the client is, who controls a corporation, what the origin of the funds is, what economic activity generates the wealth, and what risks the relationship may represent; in certain cases, it also needs to review corporate structures, trusts, intermediaries, and ultimate beneficial owners.

Complexity increases when the client comes from a jurisdiction with higher risks of corruption, sanctions, money laundering, or hard-to-verify wealth structures. The cost does not end with account opening; information must be updated, operations must be monitored, and alerts must be investigated when appropriate.

FinCEN’s customer due diligence rule specifically seeks to have financial institutions identify and verify the ultimate beneficial owners of their corporate clients. In February 2026, FinCEN granted relief regarding the obligation to identify and verify ultimate beneficial owners in each new account opening, but that does not eliminate the general responsibility to know the client and manage their risks.

For a global bank, these tasks can be integrated into technological platforms, operations centers, and specialized teams. For a small firm, they can mean hiring external personnel, acquiring monitoring tools, or relying on specialized providers; the difference is not only in how much it costs to comply, but in how many clients and assets can absorb that cost.

FATCA: the cost of serving international wealth

The Foreign Account Tax Compliance Act, known as FATCA, is one of the pillars of the US international tax transparency environment. The law seeks to identify US taxpayers who maintain accounts and financial assets outside the country. To do this, it imposes reporting obligations on foreign financial institutions and establishes reporting mechanisms to the IRS. The importance of FATCA for the offshore business is that it turns tax information management into a structural part of international financial relationships; foreign institutions that do not comply with certain obligations may face a 30% withholding on certain US-source payments, in addition to other operational and tax consequences.

For a bank or fund manager, this implies client tax classification processes, documentation, reporting, and controls to avoid errors; the burden can be particularly relevant for institutions managing structures with investors from different countries, currencies, and tax regimes. However, not all Latin American clients are subject to the same obligations. A Mexican investor using a US structure does not necessarily have the same responsibilities as a US citizen with assets abroad. The legal nature of the entity, tax residency, and the type of investment are decisive. Therefore, compliance cannot be treated as a uniform routine procedure; it is actually a process requiring specialists capable of distinguishing between profiles and structures.

Fixed costs, a real problem

As a general rule, the discussion about compliance usually concentrates on fines, sanctions, and regulatory obligations. However, to analyze competition between institutions, the most important aspect may be another: fixed costs. An international private bank may need dedicated teams for tasks such as: anti-money laundering and prevention of terrorist financing, due diligence and periodic client review, international sanctions and transaction controls, regulatory and tax reporting, internal audit and risk management, monitoring technology and records management, as well as legal and tax advisory.

That is why the number of employees, software licenses, and technological infrastructure do not necessarily grow in the same proportion as assets under management, and scale can become an advantage factor. If an institution manages very large wealth, the cost of compliance represents a smaller proportion of its potential revenues. In contrast, a small firm may face a much heavier burden for every dollar managed.

Is the business concentrating?

If regulatory costs become harder to absorb, institutions can react in several ways. One option is to invest in technology and automation, another is to hire external compliance services, but they can also specialize in a type of client or reduce their exposure to higher-risk jurisdictions. In some cases, the way out may be selling the operation, merging with another firm, or becoming part of a larger platform; the potential result is greater market concentration.

But here it is convenient to avoid an automatic conclusion because regulation is not the only factor that determines industry consolidation; interest rates, product profitability, access to technology, competition for talent, and the capacity to attract clients also exert influence. Furthermore, small firms can have advantages that large banks do not always possess: specialization, closeness to the client, knowledge of a region, and the capacity to offer personalized services. The problem appears when that specialization no longer offsets the costs of operating.

US regulatory change: fewer reports does not mean fewer controls

The 2026 juncture introduced an important nuance. FinCEN published a final rule in August that keeps US companies exempt from reporting beneficial ownership information under the Corporate Transparency Act. The obligation is maintained for certain foreign companies registered to operate in the United States. The change reduces certain formal obligations for US companies, but does not eliminate customer due diligence responsibilities for financial institutions. In other words, a company may be exempt from filing a specific report with FinCEN and, even so, have to provide information to its bank or investment manager so that it can comply with its know-your-customer obligations.

The distinction is fundamental for the offshore market; corporate transparency and financial compliance are related, but they are not exactly the same thing. The former refers to information that must be reported to authorities under a given regime; the latter encompasses risk management that financial institutions must perform as part of their operations. The reduction of one obligation does not automatically eliminate the other, and for wealth managers, regulatory uncertainty also carries a cost. A firm that invests in systems, personnel, and processes needs to know whether the rules that justified that investment will remain in force. Normative volatility can complicate planning and favor institutions that have legal and regulatory teams capable of adapting quickly.

But the impact is not limited to banks and asset managers; family offices, particularly those managing international wealth, must also face decisions related to corporate structures, private investments, investment vehicles, estate succession, and family governance. Not all family offices have the same structure. Some are single-family offices with few employees; others operate as platforms that serve several families and offer investment services, wealth administration, and tax coordination.

The difference in scale can also determine how they absorb compliance; an office managing the wealth of a single family may need to hire external providers for specialized functions, while a multi-family platform can distribute some costs among several clients. But a limit exists because outsourcing does not eliminate the manager’s responsibility. Hiring a compliance provider does not mean automatically transferring all legal and regulatory obligations. That is why the growth of the family office market can open opportunities for companies offering specialized compliance services, regulatory technology, and risk management; compliance ceases to be solely an expense and becomes a service industry around international wealth. The transformation of the offshore market can also create winners other than banks; regulatory technology companies, identity verification providers, transaction monitoring platforms, and specialized firms can benefit from structural demand.

The financial industry needs tools to reduce errors, accelerate processes, and keep its clients’ information updated; additionally, artificial intelligence can contribute to automating some tasks of review, classification, and anomaly detection, but its use does not eliminate the need for human controls, validation, and institutional responsibility. For small firms, technology can represent a way to compete with large institutions without replicating all their internal infrastructure; the challenge is that technology also requires investment, integration, and maintenance. Furthermore, automated systems can generate false positives, classification errors, and data quality issues. The question is no longer only how much it costs to comply, but how much it costs to comply efficiently.

An offshore market for the big players?

Based on the above, everything indicates that there are indeed economic reasons to think that scale can favor large institutions because fixed costs, technological investment capacity, and the availability of specialists can generate competitive advantages. But it is not enough to state that the US offshore is becoming an exclusive business for the big players; competition also depends on the ability of small firms to specialize, outsource functions, automate processes, and carefully select their clients.

The most probable scenario is not necessarily the disappearance of the small ones, but a more marked differentiation between business models; on one hand, large banks and platforms can offer comprehensive services, global infrastructure, and capacity to serve complex wealth. On the other, boutique firms can compete through regional specialization, personalized attention, and knowledge of specific segments of the Latin American market. The problem is that regulation can raise the minimum operating threshold. An institution that previously could serve a small number of international clients with a relatively simple structure may now need more sophisticated processes to remain competitive.

The US offshore market was born and developed around the capacity to attract international capital, offer sophisticated financial services, and connect investors with global markets. Today, a growing part of competition may depend on something less visible: the ability to comply. The bank that best identifies risks, the manager that maintains stronger files, and the platform that automates its processes can have an advantage over their competitors, but that advantage has a cost.

For investors, compliance can mean greater security, transparency, and trust; for institutions, it represents instead a necessary investment to operate. And for small firms, it can become the difference between growing, specializing, or abandoning certain market segments. The question is not whether the offshore must comply, but who can pay the price of doing so and what effects that cost will have on competition. Because in the new map of international money, the capacity to manage wealth may continue to be important, but the capacity to demonstrate that it is managed correctly may be the one that determines who remains in business.