Witherspoon, Carroll and Perfetti Examine Compliance Challenges in New Agentic Payments Framework in Law360

06.01.2026

Stinson LLP Partner Tom Witherspoon and attorneys Audrey Carroll and Marisa Perfetti authored an "Expert Analysis" column for Law360 examining how Visa's recently released framework for agentic payments could create new compliance challenges as automated purchasing technologies continue to evolve.

In the article, "Visa's Agentic Payment Rules Expose Compliance Tensions," the authors discuss how Visa's framework establishes rules for transactions completed by agentic payment providers that make purchases on behalf of consumers based on predetermined instructions. They note that while the framework is designed to support emerging forms of automated commerce, many existing consumer protection laws were built around direct interactions between merchants and consumers.

"The rise of agentic payments exposes a growing tension between evolving payment infrastructure and legacy consumer protection regimes," the authors write. "While Visa's framework formalizes a model in which [agentic payment] providers act as transactional intermediaries, most regulatory obligations still presuppose a direct merchant-consumer relationship at the point of sale."

The article explores how business may need to navigate a complex and evolving compliance landscape as agentic payment providers become more sophisticated and consumer transactions increasingly involve multiple parties.

Witherspoon's practice focuses on payments, consumer financial products and other bank and financial regulatory matters with an emphasis on compliance, financial transactional and litigation matters.

Carroll's practice focuses on complex matters involving financial services, payments systems and virtual currency, advising financial institutions and FinTech companies on regulatory and contractual matters.

Perfetti focuses her practice on a broad range of complex banking and financial services matters, advising clients from FinTech startups to established financial institutions.

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