AI Compliance Playbook: Adapting the Three Lines Framework for AI Innovations

Facing imminent AI regulation, companies using AI are looking to the respected “Three Lines of Defense” risk management framework to help them reassure the public and regulators, but are finding that the framework’s rigor clashes with the ethics-by-design thinking. This article explains how to adapt the Three Lines approach to AI/ML and includes actions to take during AI development and deployment, described by experts at bnh.ai, the Future of Privacy Forum, Linklaters and Mayer Brown. It also provides insights from AI specialists at Microsoft and Morrison & Foerster, delivered during recent IAPP and Privacy + Security Forum panels. See our AI Compliance Playbook series: “Traditional Risk Controls for Cutting-Edge Algorithms” (Apr. 14, 2021); “Seven Questions to Ask Before Regulators or Reporters Do” (Apr. 21, 2021); and “Understanding Algorithm Audits” (Apr. 28, 2021). 

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