FINRA member firms (“Members”), and the enterprise organizations in which many sit, are moving rapidly to deploy firm-approved artificial intelligence tools for use by their employees. As adoption accelerates, the available tools (and employees’ ability and willingness to use them) will increase dramatically.
The vast majority of employees will properly utilize AI technology, just as they have prior technologies. Policies and procedures will be written and followed, and hopefully customer harm can be avoided. Nevertheless, as with any new technology, firms should remain mindful that AI may create opportunities for misuse, circumvention of established controls, or unintended compliance issues. Appropriate governance, supervision, and monitoring remain important.
The purpose of this GT Alert is to identify categories of issues that firms may begin to encounter involving their employees’ use of AI in ways that cause customer harm or violate firm policies and procedures. Drawing on misconduct patterns observed in internal reviews conducted over the past two decades, and recognizing well-established motivations for employee misconduct, this Alert identifies several areas that firms may wish to consider for review.