Cyber IT Supervisory Forum eBook

Notional AI Adoption and Implementation Stages * Description Stage AI has not yet been adopted by the organization, but the organization needs to take a proactive defensive posture to avoid AI-related risks. Proactive Defense The organization deploys various software products that have embedded AI functionality for targeted applications. Embedded Capability Deployment

Exploratory Development

The organization is exploring one or more potential AI use cases, developed internally, and needs to begin putting in place a foundational control structure. AI is implemented in one or a small number of low-risk production use cases (e.g., not customer-facing, not affecting transactional activity, not affecting financial reporting). AI is implemented in one or a small number of moderate-risk production use cases (e.g., customer-facing but not affecting transactional activity, not affecting financial reporting). AI is implemented in one or a small number of high-risk production use cases (e.g., customer-facing and affecting transactional activity, affecting financial reporting). AI has become broadly adopted across the organization and is employed across a number of different use cases.

Low-Impact Use

Moderate-Impact Use

Increasing Risk Level

High-Impact Use

Broad-Based AI Adoption

* Note: These stages are not necessarily progressive; firms often jump directly to a specific stage.

CRI AI Implementation Guidance – Conceptual Framework

AI Adoption / Implementation Stages

Embedded Capability Deployment

NIST AI RMF

Proactive Defense

Exploratory Development

Low-Impact Use

Moderate Impact Use

High-Impact Use

Broad-Based AI Adoption

Govern

Govern 1 Govern 2

Map

Subcategory-Level Guidance / Control Objectives

Map 1 Map 2 Measure

Map to CRI Profile where relevant

Measure 1 Measure 2

Manage Measure

Measure 2

Also informed by: • OCC Model Risk Guidance • MITRE ATT&CK for Learning Systems (ATLAS) • OWASP LLM Top 10 • Machine Learning Security Top 10 • ISO 42001

FS-Tailored Control Implementation Guidance

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