42% of enterprises abandoned most AI initiatives in 2025—up from 17% a year earlier—and 46% scrapped their proof-of-concepts before production [1].
The problem isn't the models. It's the infrastructure beneath them.
While enterprises haemorrhage billions on failed pilots, a counter-trend is emerging: firms with embedded governance infrastructure are capturing measurable returns.
JPMorgan: ≈ $2B in value from $2B AI investment [3]
HSBC: 2–4× fraud detection, ~60% fewer false alerts [4]
Mastercard: 20–300% fraud-detection uplift [5]
The difference? Policy-as-code, provenance, and validation—built in, not bolted on.
Pilot Purgatory—AI Built on Sand
95% of GenAI pilots fail to deliver ROI (MIT NANDA 2025 [6])
Projects stall on lineage, explainability, and auditability—not model accuracy
Result: endless proofs-of-concept that no regulator will approve
"Pilot Purgatory" is where enterprises stay busy building AI that no auditor can trust.
The Hidden Tax—Manual Governance at Scale
Compliance teams burn thousands of hours reconstructing lineage for every AI decision.
JPMorgan's COiN system saved ≈ 360,000 work hours annually [3]
Audit prep: weeks → months, dozens of FTEs per cycle
Each failed implementation costs $500K–$5M in lost opportunity
Manual governance doesn't scale. Policy-as-code does.
The Governance Fabric—Turning Compliance into Product
The winners aren't "adding governance." They've productised it.
Policy Store—Network-Effect Moat
Machine-readable rules versioned like code, mapped to EU AI Act, ISO 42001, NIST AI RMF, UCP600 and URDG758 [7][8].
Each new policy expands coverage and compounds value. Competitors can copy features—not the accumulated governance fabric.
Trade Graph—Data Network Moat
A reasoning-grade graph linking entities, instruments, obligations, jurisdictions and document lineage—built for deterministic checks and explainable decisions [9][10].
Graph density compounds over time; competitors starting with empty graphs face 18–24 months of relationship encoding just to catch up.
Provenance by Default—Regulatory Moat
Every decision binds data lineage + policy version + model ID + human oversight.
Audit packages in minutes, not months [11]. Bolt-on provenance breaks; built-in scales.
"AI has the potential to support prudential objectives… Rapid advancements in AI offer new capabilities for financial institutions to fulfil regulatory requirements in a more effective and efficient way."
— Bank for International Settlements, FSI Insights No. 63 (2024)
Example Workflow—LC Discrepancy Resolution
Legacy (Pilot Purgatory):
Analyst receives flagged Letter of Credit → manually checks UCP600 Art 14(a) → reviews 40-page document set → consults policy manual → escalates → decision ≈ 4 hours.
TradeQu (Governance Fabric):
System ingests LC → Trade Graph maps beneficiary / issuing bank / jurisdiction → Policy Store executes UCP600 Art 14(a) as code → flags 3 discrepancies with line-level citations → provenance log binds [policy v2.1 + doc hashes + rule application] → analyst reviews summary in 6 minutes → decision with full audit trail.
Change: 4 hours → 6 minutes (40× faster) with superior compliance documentation.
The Compliance Dividend—Where the Budget Comes From
Global financial-crime compliance spend ≈ $206B / year [12][13]
30–50% automatable via policy-as-code → $60–100B addressable
Capturing even 10% of that reallocation = $6–10B market—10× today's AI-governance sector [14][15]
Every $1 shifted from manual compliance to automated governance buys 3–5× more coverage at lower error rates.
Before / After—HSBC AML Transformation
Metric | Before | After | Change |
|---|---|---|---|
Transactions / month | 1.35B | 1.35B | — |
Detection rate | Baseline | 2–4× ↑ | +100–300% |
False positives | High | –60% | Analyst hours freed |
Audit prep time | Weeks | Days | 5–10× faster |
Lesson: HSBC didn't add AI to old processes—they rebuilt the infrastructure governance-first [4][22].
Why Now—Regulators, Markets & Moats Converge
EU AI Act: Fines up to €35M or 7% global turnover [16]
BIS / FSI: Governance = bottleneck + prudential path [17]
BoE & IMF (Oct 2025): Warn of AI valuation bubble and "sharp correction" risk [18][19]
The window is closing. Governance is a Q4 2025 imperative—not a 2026 option.
Common Objections
"We already have a governance framework."
PDF guidelines aren't executable policies. Can you prove every decision in five minutes?
"Our vendor will add governance."
Bolt-on provenance breaks under edge cases. Built-in scales.
"This sounds like rip-and-replace."
Zero-copy integration means no data migration—we bind metadata and emit audit trails alongside existing systems.
Early Adopter Program—Preparing for Launch
TradeQu's Early Adopter Program is forming now for a Q4 2025 / Q1 2026 launch.
We're curating a small group of institutions to co-design governance workflows and generate the first compliance-dividend benchmarks before EU AI Act enforcement accelerates in 2026.
Who it's for
Banks, trade platforms and corporates with regulated workflows (L/Cs, guarantees, sanctions checks)
Policy and data owners ready to pilot governance fabric in controlled environments
What we'll do together
Select a high-leverage workflow (e.g. L/C discrepancy triage)
Encode policies as code in the Policy Store
Bind decisions to evidence (lineage + policy + model + human)
Shadow-run vs. current process to measure impact
Deliver a Compliance Dividend Report quantifying OPEX reallocation and risk reduction
Engagement model
Zero-copy integration
Time-boxed milestones with clear exit criteria
Regulator-ready documentation aligned to ISO 42001 / NIST AI RMF
Governance Maturity Self-Assessment
Question | 0 (None) | 1 (Ad-hoc) | 2 (Systematic) | 3 (Embedded) |
|---|---|---|---|---|
Prove every AI decision (policy + lineage)? | No | Manual | Versioned | Real-time |
Automatable compliance via policy-as-code | < 10% | 10–30% | 30–60% | > 60% |
Black-box automation regulators could challenge | Everywhere | Some | Few | None |
Audit evidence time (random decision) | Weeks | Days | Hours | Minutes |
Governance is (cost or moat) | Cost | Breakeven | ROI | Strategic |
Interpretation
Score Range | Category | Description | Next Step |
|---|---|---|---|
0–5 | Pilot Purgatory | No governance infrastructure; projects fail at compliance review | Pause new pilots; run one shadow workflow to test governance fabric |
6–10 | Transitional | Governance pieces exist but scattered | Consolidate into one fabric; convert a high-risk workflow to policy-as-code |
11–15 | Governance-Native | Systemic, auditable governance in place | Expand policy coverage and quantify your compliance dividend |
The 2027 Divide—Governance Haves vs. Have-Nots
Tier 1 (Governance-Native)
60–80% of compliance workflows policy-automated
Audit packs in hours; fast-track approvals
Compliance shifts from $206B cost to competitive moat
Tier 2 (Legacy)
42–95% AI project failure
Manual costs rising; audit delays mounting
Trust and market share erode
Governance infrastructure is the dividing line between AI that fails quietly and AI that scales safely.
Join the Early Adopter Program
Turn governance into ROI.
Join TradeQu's Early Adopter Cohort (Q4 2025 / Q1 2026, limited to 6 institutions) to co-design a policy-to-proof workflow and quantify your compliance dividend before EU AI Act enforcement accelerates.
References
[1] S&P Global Market Intelligence (2025): AI in the Enterprise 2025—42% abandoned initiatives; 46% scrapped POCs.
[2] Gartner Hype Cycle for Gen AI 2025.
[3] JPMorgan CEO Jamie Dimon, Entrepreneur (2025).
[4] HSBC / Google Cloud Dynamic Risk Assessment (2024).
[5] Mastercard Decision Intelligence Pro Press Release (Feb 2024).
[6] MIT NANDA Initiative (Aug 2025).
[7] ISO 42001 (2023).
[8] NIST AI RMF 1.0 (2023).
[9] DeepOpinion Trade Document Intelligence (2024).
[10] BNP Paribas "How AI Optimises Trade Finance" (2024).
[11] EY / Goodwin (2024): EU AI Act Traceability Requirements.
[12] LexisNexis Risk Solutions (2023).
[13] Oxford Economics (2023).
[14] Grand View Research (2024).
[15] Markets and Markets (2025).
[16] EU AI Act (2024).
[17] BIS FSI Insights No. 63 (2024).
[18] Bank of England FPC Record (Oct 2025).
[19] IMF World Economic Outlook (Oct 2025).
Authorship Declaration
Written by Sam Carter — TradeQu Labs.
Research and drafting assisted by ChatGPT (GPT-5), Perplexity Research, and Claude 3 Opus. All sources verified through human review. This article adheres to TradeQu’s principle of transparent AI-assisted research and publication.Transparent AI collaboration — authored and verified by TradeQu Labs.
We’re always looking for collaborators exploring how intelligence can become verifiable.
Let’s build the future of compliant AI together.
If your institution is exploring AI governance, policy-as-code, or explainable infrastructure, we’d like to collaborate.



