CHAPTER 2: AI Governance Gaps – The Risk of AI Principles Without Practice

by | Mar 30, 2025

ARiMI Learning Series:

AI FOR RISK PROFESSIONALS & LEADERS

This chapter is part of the “AI For Risk Professionals & Leaders” learning series, designed to help risk professionals and leaders engage with AI in ways that complement sound judgment, strategic thinking and ethical practice. Whether you are a certified expert or a curious practitioner, each chapter offers practical guidance to support the confident, clear and responsible use of AI tools in risk management.

 


The Risk of AI Principles Without Practice

As organisations accelerate their adoption of AI technologies, there’s a growing emphasis on establishing AI governance frameworks. Many firms have begun publishing ethical guidelines, forming AI steering committees, and developing internal policies to guide responsible AI use. Yet, a persistent gap remains between principles and practice.

This gap often reveals itself when ethical AI guidelines are in place, but practical implementation falls short. Risk professionals must go beyond endorsing responsible AI and instead ensure that governance mechanisms are embedded, enforceable, and adaptable to real-world complexity. Without this operational grounding, even well-intentioned AI policies can become little more than aspirational statements.


From Vision Statements to Operational Reality

Ethical frameworks for AI typically emphasise fairness, transparency, accountability, and human oversight. These principles are foundational, but they are not governance in themselves.

In many cases, organisations adopt AI principles without having the processes, expertise, or internal controls to apply them effectively. This can result in:

Governance Weakness Organisational Risk
Vague guidelines Inconsistent application and interpretation
Lack of auditability Limited ability to trace decisions or flag misuse
Over reliance on vendors Reduced control and oversight over third-party AI systems
No ownership model Diffused accountability across departments
Static policies Misalignment with evolving tools and regulatory expectations

As AI systems evolve rapidly, governance must be proactive, not reactive. It should include clear roles, escalation protocols, documentation standards, and mechanisms to evaluate outcomes, not just intentions.


Bridging the Gap: The Role of Risk Professionals

AI governance is not the sole responsibility of data scientists or IT teams. Risk professionals play a central role in ensuring that AI is used in a manner consistent with enterprise risk appetite, legal obligations, and public trust.

Risk professionals must:

  • Translate high-level principles into operational safeguards

  • Identify potential failure points and unintended consequences

  • Ensure that risk registers reflect AI-specific risks

  • Collaborate with legal, compliance, and IT teams to monitor AI deployment

  • Build review loops into AI use cases to capture learning and refine controls

Governance becomes meaningful only when it is translated into daily decisions and embedded across functions.


The Illusion of Safety in Checklists

One common pitfall in AI governance is the belief that having a checklist or compliance framework is sufficient. While checklists are useful, they are not a substitute for critical thinking and continuous oversight.

AI systems, especially those powered by generative models, are dynamic, context-dependent, and often unpredictable. Risk professionals need to remain vigilant and continuously re-evaluate governance measures based on:

  • Changes in AI model behaviour

  • New or evolving regulatory guidance

  • Shifts in business use cases

  • Incidents and feedback from system users or impacted stakeholders

True governance is an active process, not a one-time box-ticking exercise.


Embedding Governance Through Lifecycle Thinking

AI systems, like any major technology, go through a lifecycle: from design and development to deployment and eventual retirement. Governance should be applied throughout this lifecycle.

AI Lifecycle Stage Governance Focus
Design & Development Bias mitigation, ethical design, and explainability
Testing & Validation Accuracy, robustness, and alignment with intended use
Deployment Access controls, user permissions, and integration safeguards
Monitoring & Feedback Incident reporting, retraining protocols, and audit trails
Retirement Responsible decommissioning and data handling policies

Risk professionals must ensure that controls are dynamic and evolve with each stage, maintaining visibility and integrity across the entire AI value chain.


The Myth of ‘Ethical by Design’

The idea that AI can be made fully ethical through design alone is appealing, but misleading. While responsible design is a critical foundation, it does not absolve organisations of the need for ongoing oversight, stakeholder engagement, and adaptive governance.

AI is shaped not only by its architecture and algorithms, but also by how it is applied, by whom, and in what context. Risk professionals must resist the temptation to treat AI governance as a static engineering problem. It is a living process, shaped by people, processes, and values.


Building Cross-Functional Governance Teams

AI governance cannot thrive in silos. It requires collaboration between technical, operational, and strategic functions. Risk professionals should advocate for governance teams that include:

  • Technical leads to explain model behaviours and limitations

  • Legal and compliance experts to address regulatory concerns

  • Ethics advisors to reflect stakeholder impact

  • Operational leads to align with business context

  • Risk and audit professionals to ensure controls are working as intended

When governance is shared, it becomes more robust, nuanced, and enforceable.


Supporting Risk Culture with Real Governance

A strong risk culture includes not only awareness of AI risks, but also the discipline to manage them. ARiMI encourages the use of governance practices that empower professionals to make ethical, informed decisions about AI use, even in the face of complexity and pressure to deliver fast results.

Certified risk professionals can act as stewards of governance, ensuring that AI initiatives are not just compliant on paper, but responsible in practice. This includes:

  • Escalating when AI usage conflicts with organisational values

  • Recommending pauses or revisions when controls are inadequate

  • Acting as a conscience for leadership when short-term gains conflict with long-term integrity


A Foundation for AI-Integrated Risk Management

Governance is not a one-time activity. It is an ongoing commitment. For organisations to integrate AI responsibly into their risk functions, governance gaps must be actively identified and closed.

This chapter is designed to help risk professionals strengthen their role in AI oversight, not just by understanding governance principles, but by applying them in practice. To support this journey, ARiMI is developing a structured learning experience that will extend beyond this series.

Each chapter will form the foundation of a dedicated learning module. These modules will be expanded into a broader set of resources that may include implementation guides, checklists, diagnostic tools, and case-based exercises. Together, they are intended to support practical application and structured reflection in professional settings.

Learners will also have the option to complete short assessments tied to each module. These assessments will contribute toward a certification pathway designed to validate the ability to apply AI responsibly, ethically, and effectively within the discipline of risk management.

Future chapters will continue building this foundation by exploring accountability structures, risk appetite calibration, and strategies for embedding AI into enterprise risk frameworks without compromising sound judgment or professional discipline.