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Da Vinci Week: Part 3 – Leonardo’s Flying Machines and “Can We?” or “Should We?”

In the first two posts in the Leonardo Compliance Framework, the Mona Lisa gave us Refine, the principle that an effective compliance program improves as the organization learns from experience. Leonardo’s anatomical studies gave us Investigate, the discipline of looking beneath misconduct to understand root causes, control failures, incentives, management decisions, and the organizational systems that produced the outcome. The third principle is Innovate.

For that lesson, we turn to Leonardo’s studies of flight and his designs for flying machines. Leonardo examined birds, air movement, wings, and mechanical systems as he considered whether technology could allow human beings to fly. Many of his concepts were far beyond the practical capabilities of his time, but they demonstrate an important characteristic of Leonardo’s work: he imagined capabilities that did not yet exist and then studied the systems necessary to make them possible.

For corporate compliance professionals in 2026, the analogy to artificial intelligence is particularly useful. AI is expanding what companies can automate, analyze, predict, generate, and increasingly act upon. Organizations are moving beyond using generative AI to draft documents and summarize information. AI systems are becoming embedded in business processes, interacting with corporate data, supporting consequential decisions, communicating with customers, evaluating third parties, and, through increasingly agentic capabilities, taking actions that previously required human intervention.

The compliance challenge is not whether companies should innovate. They will. The challenge is establishing governance that lets innovation create business value without creating unmanaged legal, ethical, operational, or compliance risk.

AI Governance Is Enterprise Governance

Compliance professionals have sometimes approached emerging technology as primarily the responsibility of IT, Cybersecurity, Data Privacy, or Legal. That division becomes increasingly difficult with AI because these systems can influence many of the activities a corporate compliance team already oversees. Indeed, the Evaluation of Corporate Compliance Programs (ECCP) anticipates these very concepts in its 2024 edition.

AI may assist with third-party due diligence, contract review, procurement, transaction analysis, hiring, customer communications, investigations, fraud detection, marketing, or pricing. Each application creates a different risk profile. A due diligence system may generate inaccurate information about a business partner. An investigation tool may expose privileged or confidential information. A sales application may generate communications inconsistent with company policies. An agent connected to corporate systems may take actions that historically required human approval.

The ECCP asks the following:

  • How does the company assess the potential impact of new technologies, such as artificial intelligence (AI), on its ability to comply with criminal laws?
  • Is management of risks related to the use of AI and other new technologies integrated into broader enterprise risk management (ERM) strategies?
  • What is the company’s approach to governance regarding the use of new technologies such as AI in its commercial business and in its compliance program?
  • How is the company curbing any potential negative or unintended consequences resulting from the use of technologies, both in its commercial business and in its compliance program? 

Visibility and Risk Should Drive the Control Environment

By 2026, asking whether a company uses AI provides little useful information. Management needs to understand how AI is being used and what authority particular systems possess. A tool that summarizes a public document presents a very different risk profile from a system that influences hiring, approves a third party, communicates with customers, accesses confidential information, initiates a transaction, changes corporate records, or takes actions across interconnected systems.

An AI inventory should therefore identify meaningful use cases, including the business owner, intended purpose, relevant data, third parties involved, decisions influenced by the technology, degree of autonomy, and applicable controls. The objective is not simply to count tools. It is to give management sufficient visibility to identify where material risk exists.

That visibility should support risk classification. Not every AI application requires the same level of governance. Classification should consider the system’s purpose, data sensitivity, potential consequences of error, degree of autonomy, affected populations, ability to review or reverse decisions, and applicable legal or regulatory requirements.

This is familiar territory for compliance professionals. Risk-based programs have long applied different levels of scrutiny to third parties, transactions, investigations, and markets. AI should follow the same principle. Higher-risk systems should receive greater review, stronger controls, and more rigorous monitoring.

Human Oversight Must Preserve Accountability

“Human in the loop” has become common language in AI governance, but a human’s presence alone does not create an effective control. Meaningful oversight requires defined responsibilities, appropriate expertise, sufficient capacity to review relevant outputs, and authority to challenge or override the system.

If one employee is nominally responsible for reviewing thousands of AI-generated recommendations each day, human oversight may exist on paper but not function in practice. The same problem arises when employees routinely accept recommendations because they assume the technology is more reliable than their own judgment.

The control should therefore define the reviewer’s responsibilities, the circumstances requiring additional scrutiny, the authority to reject recommendations, and how to handle material overrides or recurring disagreements between the system and human decision-makers. Most importantly, technology should not create an accountability vacuum. If an AI system contributes to a compliance failure, the organization should still be able to identify the business process owner, who approved the use case, who monitored it, and who had authority to intervene.

This becomes increasingly important with agentic systems. Traditional corporate controls generally assume identifiable human actors approve payments, create vendors, review contracts, or authorize higher-risk third parties. When technology performs some of those activities, the organization has effectively delegated authority to a system. The control environment must reflect that delegation while retaining human and organizational accountability for the outcome.

Third-Party AI and Data Risk

Many companies will obtain significant AI capabilities from external vendors rather than develop them internally. Using a vendor does not transfer accountability for the resulting compliance risk. Traditional third-party risk management principles remain relevant. The company should understand the service provided, the information the vendor receives, how data are used and retained, which subcontractors are involved, how incidents are managed, and what contractual rights the company has to obtain information, require remediation, audit, or terminate the relationship.

AI adds a dynamic element because models, features, and business uses can change after initial approval. Monitoring should therefore identify material changes in functionality, data use, vendor practices, or business application that could alter the original risk assessment.

Data governance is equally important. Companies need clear rules regarding which AI systems may access confidential business information, personal data, investigation materials, privileged communications, customer information, trade secrets, source code, and other sensitive information. As enterprise AI systems increasingly operate on internal data, blanket prohibitions will often give way to more precise governance defining approved systems, permissible data, access controls, retention, deletion, and accountability.

These issues require coordination across Compliance, Legal, Privacy, Cybersecurity, IT, Records Management, and the business. Effective governance depends upon clear responsibilities rather than overlapping or fragmented ownership.

Test Before Deployment and Monitor Afterward

Leonardo’s flying machines provide another useful innovation lesson. Test a design before you trust it with a critical task. AI testing should match the risk. Before deployment, the company should understand whether the system performs as intended, where its limitations lie, how it responds to unusual circumstances, whether users can manipulate it, and whether inaccurate or inconsistent outputs could create material consequences. Testing at implementation is not enough. Business conditions change, vendors update models, employees develop new uses, and system capabilities expand. An application that operated within acceptable parameters when approved may later present a different risk profile.

Higher-risk systems therefore require post-deployment monitoring that can identify performance issues, material changes, incidents, and circumstances requiring reassessment. Management should also establish when a system should be modified, restricted, or suspended.

This lifecycle approach connects Innovate to the next Leonardo principle, Monitor. Responsible innovation is not a one-time approval. Governance should continue throughout the period the organization relies on the technology.

Using NIST and ISO as Governance Architecture

Compliance professionals do not need to invent an AI governance structure from scratch. The NIST AI Risk Management Framework provides a useful approach to governance, mapping, measuring, and managing AI risk, while ISO/IEC 42001 offers a management-system perspective built around responsibilities, processes, documentation, monitoring, and continuous improvement.

For the CCO, the value lies in providing governance architecture, not another checklist. The relevant measure is not whether a company can say it follows NIST or ISO. It is whether its governance system addresses the actual risks created by its AI applications and whether the resulting controls work in practice. Frameworks provide structure. Management remains responsible for operating the system.

Compliance Should Enable Responsible Innovation

The CCO should avoid two extremes: allowing enthusiasm for AI to outrun governance or creating an approval structure so burdensome that employees circumvent it. A better model is responsible innovation. Compliance can help create clear pathways for lower-risk experimentation while ensuring that higher-risk applications receive appropriate scrutiny. Employees should understand what uses are permitted, which require approval, what categories of information may be used, and when escalation is necessary.

This approach also creates opportunities for a corporate compliance program. AI may improve due diligence, transaction monitoring, investigations, risk assessment, training, and data analysis. The compliance function should be willing to explore those capabilities under the same risk-based governance it expects the business to follow.

A CCO’s contribution should not be measured by how much innovation Compliance prevents. It should be measured in part by whether Compliance helps the enterprise capture value while maintaining appropriate accountability and control.

Before Leaving the Ground

Leonardo’s flying-machine studies represent the willingness to imagine possibilities beyond current practice. The modern compliance lesson is to combine that willingness with disciplined governance. For the CCO, Innovate means helping the enterprise pursue new capabilities through a risk-based system that provides visibility, assigns ownership, preserves meaningful human accountability, tests higher-risk applications, and monitors them as technology and business use evolve. The objective is neither unrestricted adoption nor blanket prohibition. It is responsible innovation that can produce sustainable business value.

From Innovation to Monitoring

Responsible innovation does not end when technology is approved and deployed. The organization must determine whether systems continue to operate as intended as data, users, vendors, business conditions, and risks change. That brings us to the fourth Leonardo principle: Monitor.

In Blog Post Four, The Last Supper and the Danger of Deterioration, we will use Leonardo’s experimental masterpiece to examine the difference between implementing a control and demonstrating that it remains effective. The discussion will focus on control testing, continuous monitoring, compliance analytics, ownership, remediation, AI monitoring, and the board’s role in evaluating evidence of continuing program effectiveness.

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AI Today in 5

AI Today in 5: September 16, 2026, The False Choice Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. The difference between AI pilots and AI. (Federal News Network)
  2. AI for Supply chain compliance. (ESG News)
  3. AI governance is pressing in healthcare. (Healthcare IT News)
  4. Enterprise AI enters a new era in banking. (FinTech Futures)
  5. Jensen Huang says you can have AI innovation and safety. (FT)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

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AI Today in 5

AI Today in 5: September 9, 2026, The Wiki Incident Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. AI governance is the real test for compliance. (FinTech Global)
  2. The role of AI in manufacturing. (Deloitte)
  3. AI hacking WeChat. (NYT)
  4. OpenAI has a wiki ‘incident.’ (Reuters)
  5. Is AGI here? (Bloomberg)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

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AI Today in 5

AI Today in 5: September 8, 2026, The EU AI Stack Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. Can actuaries trust AI? (FinTech Global)
  2. How AI is transforming global trade management. (Thomson Reuters)
  3. Banks are urged to integrate compliance, culture, and AI governance. (CW)
  4. Substantiate your AI claims. (CCI)
  5. What’s in your EU AI stack? (Forkast)

My first work of general non-fiction is now out: Deluge Before Dawn, the story of the 2025 flood in Kerr County, Texas, which killed 119 people and devastated a county. It is a story of tragedy, heartbreak, survival, and resilience.

It is available on the following sites:

Amazon.com

Stoney Creek Publishing

Barnes and Noble

Texas A&M University Press

Bookshop.org

Google.Books

Walmart

This week only, the Kindle e-book version is available for $0.99 on Amazon.

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Innovation in Compliance

Innovation in Compliance: Bennett Borden on the AI Driven Law Practices of Clarion AI Partners

Innovation comes in many areas, and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom speaks with Bennett Borden of Clarion AI Partners.

Borden is a lawyer and data scientist whose career has long focused on the intersection of law, data, and technology, including AI governance, compliance, and the legal implications of generative AI. Drawing on experience at the CIA, in big law, and leading AI-focused legal practices, he views generative AI as a disruptive force reshaping both legal services and business models. Borden argues that effective AI governance requires “governance engineering”: translating legal obligations into technical controls and measurable proof of compliance rather than treating compliance as a separate burden. He also encourages lawyers and organizations to embrace AI proactively, using it to build more efficient, future-ready practices while managing risk through practical, system-level safeguards.

 

Key highlights:

  • AI-Driven Law Practice Beyond the Billable Hour
  • Compliance as guardrails for faster innovation
  • Gift, Travel, and Entertainment Sandbox Projects
  • Trust Built by Enterprise Licenses and Safeguards
  • Microsecond-by-Microsecond Compliance Proof for AI Governance

Resources

Innovation in Compliance was recently honored as the Number 4 podcast in Risk Management by 1,000,000 Podcasts

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AI in Financial Services in 5 Stories

AI in Financial Services in 5 Stories – Week Ending September 4, 2026

Welcome to AI in Financial Services in 5 Stories. A practical weekly roundup of the five most important AI developments affecting banking, insurance, payments, asset management, and fintech. Each Friday, Tom Fox will break down the top stories that matter most through the lenses of compliance, risk management, governance, and business strategy. Designed for compliance professionals, executives, legal teams, and financial services leaders, it goes beyond headlines to explain why each development matters in a highly regulated industry. The result is a concise weekly briefing that helps listeners stay current on AI innovation while asking sharper questions about oversight, accountability, and trust.

This week’s stories include the following:

  1. AI spots gaps in financial firms’ cybersecurity faster than companies can fix them. (FT)
  2. NVB urges AI for transaction monitoring. (AML Intelligence)
  3. AI puts banking governance to the test. (QA Financial)
  4. Does AI threaten the global banking system? (CNBC)
  5. How the Middle East became an AI fintech hub. (Arab News)

For more information on the use of AI in Compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on Amazon.com.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.

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AI Today in 5

AI Today in 5: September 3, 2026, The Spotting Cybersecurity Gaps Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. AI spots Cyber gaps faster than companies can fix them. (FT)
  2. OpenAI to restrict Astra. (WSJ)
  3. Is AI governance following the same path as privacy compliance? (JD Supra)
  4. NVB urges banks to embrace AI for transaction monitoring. (AML Intelligence)
  5. AML foundations must be robust for AI to work. (FinTechGlobal)

For more information on using AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on ⁠Amazon.com⁠.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

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AI Today in 5

AI Today in 5: August 28, 2026, The Just Table Stakes Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. Bill Gates warns on AI. (NYT)
  2. AI governance beyond compliance. (IAPP)
  3. CIGNA AI chief on investing in AI. (Fortune)
  4. AI is now a table stake for compliance monitoring. (National Law Review)
  5. Will Agentic AI refine banking? (International Banker)

For more information on using AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on ⁠Amazon.com⁠.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

Categories
AI Today in 5

AI Today in 5: August 25, 2026, The AI Governance Has Named Accountability Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to AI Today in 5. All from the Compliance Podcast Network. Each day, we consider five stories from the business world on compliance, ethics, risk management, leadership, or general interest in AI.

Top AI stories include:

  1. AI governance for health services. (Yahoo! Finance)
  2. AI for email compliance. (NJIT)
  3. AI in quality management. (ARC Advisory Group)
  4. AI governance is becoming a named accountability. (CCI)
  5. Bank-grade AI for compliance. (FinTechGlobal)

For more information on using AI in compliance programs, Tom Fox’s new book, Upping Your Game, is available. You can purchase a copy of the book on ⁠Amazon.com⁠.

To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on ⁠Amazon.com⁠.

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Blog

Private Company, Public Risk: Building Defensible AI Governance Before the Rules Arrive

For private companies, the central question about artificial intelligence is no longer whether the technology is in the business. It is whether anyone can explain where it is, what it does, what data it touches, and who is accountable when it fails.

That is the warning in “AI Governance for Private Companies,” by Hillary Flynn, Drew Morales, and Courtney Hugger of Wellington Management, which was recently posted in the Harvard Law School Forum on Corporate Governance. The authors report that nearly three in four companies plan to deploy agentic AI within two years, while only one in five has a mature governance model for autonomous agents. That is not merely a technology gap. It is a governance gap.

Private ownership does not make AI risk private. The consequences arrive through customers, employees, regulators, investors, lenders, insurers, and business partners. A company may not yet face a single comprehensive AI law, but it can still face a privacy complaint, contract dispute, cyber incident, customer loss, or damaged valuation. For compliance professionals, governance should precede scale.

Private Does Not Mean Exempt

Private companies are moving quickly because AI can increase productivity, improve customer service, accelerate analysis, support coding, and help a growing company scale. The article also identifies a critical lesson from Wellington’s portfolio companies: the largest barriers are often organizational, not technical. Companies making the strongest progress combine AI investment with employee training, clear governance, and defined expectations.

This is where the Chief Compliance Officer can reframe the discussion. AI governance is the discipline that allows useful experimentation without unmanaged legal and business exposure. The goal is not a thick policy on a shared drive. The goal is an operating system for accountable decisions.

The European Union AI Act is being implemented in phases through 2027, with expectations around transparency, human oversight, documentation, risk management, monitoring, and AI literacy. In the United States, NIST guidance, ISO standards, sector rules, state laws, and customer requirements are shaping expectations, even without a federal AI statute. A private company can therefore face AI governance demands through a contract or transaction long before a regulator knocks on the door.

Begin With the Business Objective

One of the article’s strongest recommendations is also one of the simplest: start with the business problem, not the AI tool. This is precisely what Carl Hahn has consistently maintained: always ask, “What is the Business Value?”Teams should define the desired outcome before selecting a model or vendor. Is it lower cost, faster response, better quality, increased revenue, fewer errors, or reduced risk?

Governance cannot evaluate an undefined promise. A measurable objective gives management a basis for deciding whether the use case works and whether its benefits justify its risks. It also creates stopping rules. Approval should identify what failure, customer impact, control breakdown, or scope change will trigger redesign, escalation, suspension, or retirement.

Compliance should insist on this discipline, particularly when an AI use case affects payments, eligibility, claims, pricing, employment, healthcare, education, financial products, or customer communications. Those are not ordinary software deployments. They are decisions and interactions with consequences for real people.

Inventory First, Then Tier the Risk

A company cannot govern what it cannot see. The foundation is an inventory of models, vendors, internal tools, embedded features, customer-facing systems, employee-built applications, and known shadow AI. It does not need to be perfect. It needs an owner, an update process, and enough information to support risk decisions.

Each use case should then be placed into a risk tier. Relevant factors include data sensitivity, degree of autonomy, importance of the business process, impact on customers or employees, regulatory exposure, ability to explain the result, and ease of reversing an error. Low-risk uses can follow a streamlined path. High-impact uses should receive enhanced testing, documented approval, human oversight, monitoring, and senior-level escalation.

Risk tiering prevents two failures. Treating every use as equally dangerous overwhelms review and encourages employees to route around it. Treating every use as ordinary technology leaves consequential applications without meaningful controls. Good governance applies greater rigor where potential harm is greater.

Put a Name Next to the Risk

Every AI system should have a business owner who remains accountable for its outcome. Accountability cannot be delegated to the model, the data science team, or the vendor. The owner should understand the intended purpose, approved users, permitted data, performance standard, escalation route, and circumstances under which the system must be paused.

Higher-risk applications should receive cross-functional review involving the business, product, engineering, legal, compliance, privacy, cybersecurity, procurement, and risk functions. This does not require a new bureaucracy. It requires a repeatable process with recorded approvals and clear responsibility.

Agentic AI raises the stakes because the risk moves from a wrong answer to a wrong action. Permissions should be limited, high-stakes actions should require human approval, and activity should be logged. Test override and shutdown mechanisms. The chatbot manipulated into agreeing to sell a vehicle for one dollar shows how weak boundaries turn a novelty into an operational event.

Treat Vendors as Part of the System

Most private companies will rely on external models, platforms, and software. That makes AI governance inseparable from third-party risk management. Traditional security questionnaires are not enough. Diligence should address how vendors use data, whether customer data trains models, how model changes are communicated, what transparency is available, how performance is tested, who bears liability, and whether data and workflows can be moved if the relationship ends.

The company should monitor model updates, service degradation, changes in terms, and features that expand access or autonomy. A tool approved for summarization should not silently become authorized to send messages, approve transactions, or alter customer records.

Monitor the System in Practice

AI governance does not end at approval. Model updates, new data, and user behavior can alter performance. Companies should monitor accuracy, reliability, bias, drift, misuse, repeated failures, and customer impact. An incident protocol should define how to pause the system, preserve evidence, escalate, remediate harm, and communicate with affected stakeholders.

This is where AI governance meets familiar compliance principles. The DOJ’s Evaluation of Corporate Compliance Programs asks whether a program works in practice. COSO emphasizes control activities, information, monitoring, and accountability. NIST’s AI Risk Management Framework helps organizations govern, map, measure, and manage AI risk. ISO/IEC 42001 offers a management-system approach. A company should select a coherent baseline and produce evidence that its controls operate.

A Practical Agenda for Boards and CCOs

Establish ownership. Name an executive accountable for AI governance and identify the board committee that will oversee material AI risk.

Build the inventory: capture sanctioned tools, embedded vendor capabilities, customer-facing uses, agentic applications, and known shadow AI.

Tier the use cases. Apply enhanced review where AI affects sensitive data, consequential decisions, critical operations, or autonomous action.

Strengthen the vendor process. Add AI-specific diligence, contractual protections, change controls, exit planning, and ongoing monitoring.

Test the failure plan. Confirm that the company can detect a harmful outcome, stop the system, preserve evidence, assign responsibility, and remediate the impact.

The author’s bottom line is the right one for compliance leaders: the winners will not necessarily be the companies that deploy AI fastest. They will be the companies that combine innovation with accountability, customer awareness, and disciplined execution. For a private company, defensible AI governance is not preparation for some distant regulatory future. It is how management protects value today.