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2020 BTLJ Comment. 1 (2020)

handle is hein.journals/btljc2020 and id is 1 raw text is: INNOVATING WITH CONFIDENCE: EMBEDDING Al
GOVERNANCE AND FAIRNESS IN A FINANCIAL
SERVICES RISK MANAGEMENT FRAMEWORK
Michelle Seng Ah Lee,t Luciano FloridAi & Alexander Denevf
ABSTRACT
An increasing number of financial services (FS) companies are adopting solutions driven
by artificial intelligence (Al) to gain operational efficiencies, derive strategic insights, and im-
prove customer engagement. However, the rate of adoption has been low, in part due to the
apprehension around its complexity and self-learning capability, which makes auditability a
challenge in a highly regulated industry. There is limited literature on how FS companies can
implement the governance and controls specific to AI-driven solutions. Al auditing cannot be
performed in a vacuum; the risks are not confined to the algorithm itself, but rather permeates
the entire organization. Using the risk of unfairness as an example, this paper will introduce
the overarching governance strategy and control framework to address the practical challenges
in mitigating risks Al introduces. With regulatory implications and industry use cases, this
framework will enable leaders to innovate with confidence.
0 2020 Michelle Seng Ah Lee, Luciano Floridi & Alexander Denev.
t University of Oxford, Deloitte UK; michelle.lee@oii.ox.ac.uk.
ft University of Oxford, Alan Turing Institute; luciano.floridi@oii.ox.ac.uk.
tt  University of Oxford, Deloitte UK; adenev@deloitte.co.uk. This research was par-
tially supported by Deloitte (MSAL and AD); and by Privacy and Trust Stream - Social lead
of the PETRAS Internet of Things research hub - PETRAS is funded by the Engineering and
Physical Sciences Research Council (EPSRC), grant agreement no. EP/N023013/1, and
Google UK Limited (LF).

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