Building an AI Governance Program from Zero
Discovered 47 shadow AI tools, implemented NIST AI RMF alignment, achieved ISO 42001 readiness, and reduced AI-related incidents by 85%, helping secure a $180M Series D.
The Challenge
A Series C fintech using ML models for credit decisioning needed a formal AI governance program before their Series D due diligence. They had no AI inventory, no bias testing protocols, and no acceptable use policies.
- 147 unsanctioned AI tools in use across engineering, marketing, and support teams
- 2ML credit models with no documented bias testing or fairness audits
- 3No AI acceptable use policy; employees using ChatGPT with customer PII
- 4Series D investors requiring demonstrable AI risk management
- 5Regulatory pressure from OCC and CFPB on AI-driven lending decisions
Our Approach
Executed the CISO Accelerator Framework to build a complete AI governance program in 4 months, from discovery through board-level reporting.
AI Discovery Audit
Conducted a full inventory of AI/ML systems across the organization. Discovered 47 shadow AI tools, classified each by risk tier (high, medium, low), and mapped data flows to identify PII exposure.
NIST AI RMF Alignment
Mapped all AI systems to the NIST AI Risk Management Framework's four functions (Govern, Map, Measure, Manage). Established risk assessment gates in the product development lifecycle.
Policy and Controls
Drafted AI acceptable use policy, model risk management procedures, and bias testing protocols. Implemented automated monitoring for model drift and data leakage.
ISO 42001 Readiness
Aligned the governance program to ISO 42001 requirements, creating the documentation and evidence trail needed for certification. Built quarterly AI risk reporting for the board.
The Results
The fintech closed its $180M Series D with AI governance cited as a differentiator by lead investors. AI incidents dropped 85% within three months of program launch.
We had AI everywhere but governance nowhere. Adil built the program that let us tell investors we take AI risk seriously. The Series D term sheet arrived two weeks after we presented the governance framework.
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