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Model Risk Governance for AI-Driven Investment

Central Banking and Monetary Policy November 30, 2025
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Introduction

The increasing reliance on complex Artificial Intelligence (AI) and Machine Learning (ML) models in investment and risk management—from portfolio optimization to anomaly detection—introduces unique and amplified forms of **Model Risk**. This specialized course is designed to equip risk and compliance professionals with the necessary framework for robustly governing these new-generation algorithms, ensuring they are safe, reliable, and compliant with official sector mandates. Participants will gain a deep understanding of the regulatory expectations (e.g., SR 11-7, Basel) as they apply to non-traditional AI models, focusing on documentation, validation, performance monitoring, and the critical challenge of **model interpretability**. The program moves beyond conceptual discussions to provide actionable strategies for establishing an end-to-end Model Risk Governance (MRG) lifecycle that effectively manages the inherent opacity and rapid deployment cycles of AI-driven systems within a reserve management context.

Objectives

Upon completion of this course, participants will be able to:

  • Articulate the distinct sources of **Model Risk** (e.g., data quality, design, implementation, use) specific to AI and Machine Learning models.
  • Design and implement a comprehensive Model Risk Governance (MRG) framework tailored for advanced quantitative and AI-driven investment strategies.
  • Develop rigorous validation methodologies, including backtesting, stress testing, and sensitivity analysis, for complex, non-linear ML models.
  • Establish clear documentation standards and a formal approval process for models throughout their entire lifecycle (development to retirement).
  • Apply **Explainable AI (XAI)** techniques (e.g., LIME, SHAP) to ensure interpretability and address the "black box" problem of deep learning models.
  • Define the roles, responsibilities, and reporting lines for the three lines of defense in an AI-driven investment environment.
  • Evaluate the ethical and compliance risks, including data privacy and bias, associated with the deployment of AI models.
  • Design a continuous performance monitoring system for real-time model drift and decay detection.

Target Audience

  • Chief Risk Officers and Heads of Model Risk Management.
  • Internal Auditors and Compliance Officers.
  • Quantitative Analysts responsible for model development and validation.
  • Heads of Investment and Technology tasked with AI adoption.
  • Regulators and Supervisors overseeing Central Banks and SWFs.
  • Senior Management responsible for investment oversight committees.

Methodology

  • Workshops on Applying XAI Techniques (LIME/SHAP) to Financial Models
  • Case Studies on Designing a Model Tiering System for a Reserve Portfolio
  • Group Exercises in Writing a Model Validation Report for a Deep Learning Algorithm
  • Discussions on Ethical AI and Bias Detection in Investment Algorithms
  • Expert Presentations on Regulatory Expectations (SR 11-7, Basel) for AI Models
  • Individual Assignments on Developing a Continuous Monitoring Dashboard Design

Personal Impact

  • Acquisition of highly specialized expertise in AI-specific model risk governance.
  • Enhanced capacity to critically evaluate and manage the risks of advanced quantitative systems.
  • Improved ability to navigate and ensure compliance with regulatory expectations for AI models.
  • Increased professional credibility as a bridge between quantitative development and risk policy.
  • Development of a strategic, risk-focused perspective on technology adoption in finance.
  • Skills to design and implement robust validation and documentation processes.

Organizational Impact

  • Mitigation of financial losses and reputational damage due to catastrophic model failure.
  • Establishment of a best-practice, future-proof **Model Risk Governance** framework.
  • Enhanced internal confidence and transparency in the use of complex AI-driven investment strategies.
  • Improved compliance with existing and forthcoming regulatory guidelines on algorithmic models.
  • A more efficient and secure process for the rapid development and deployment of new quantitative models.
  • Strengthened organizational resilience and governance oversight over the investment function.

Course Outline

Unit 1: Foundations of Model Risk in AI

Defining the Challenge:
  • Review of traditional Model Risk (e.g., SR 11-7) and its application to advanced quantitative models.
  • Unique sources of risk in AI/ML: data risk, overfitting, concept drift, and adversarial attacks.
  • The criticality of **Model Interpretability** and transparency for official sector mandates.
  • Differentiating between model design risk, implementation risk, and usage risk in an AI context.
  • Case studies of high-profile AI model failures and their financial consequences.

Unit 2: The End-to-End MRG Framework

Policy and Process:
  • Establishing a formal Model Inventory and Tiering System based on risk and materiality.
  • Designing the Model Risk Policy and Governance Charter for AI-driven investment.
  • Defining the roles and responsibilities: model owners, developers, validators, and approvers (Three Lines of Defense).
  • The Model Approval and Exception Process (MAP) for new and significantly changed AI models.

Unit 3: Validation Methodologies for AI Models

The Second Line of Defense:
  • Advanced backtesting techniques: walk-forward, cross-validation, and non-stationary time series challenges.
  • Stress-testing AI models against extreme market regimes and tail events.
  • Sensitivity analysis and input parameter stability for complex algorithms.
  • Benchmarking and comparison of AI model performance against traditional benchmarks.
  • Data validation and the critical role of independent data quality assurance.

Unit 4: Model Interpretability and Documentation

Addressing the Black Box:
  • Conceptual understanding and application of **Explainable AI (XAI)** techniques (LIME, SHAP, feature importance).
  • Establishing rigorous documentation standards: clear logic, assumptions, limitations, and governance structure.
  • The challenge of communicating model output and confidence levels to non-technical senior management.
  • Designing an audit trail and version control system for continuous model development.

Unit 5: Ethical AI, Monitoring, and Auditing

Lifecycle Management:
  • Addressing **Ethical AI** concerns: model bias, fairness, and discrimination in investment decisions.
  • Designing a continuous performance monitoring system to detect model decay and concept drift in real-time.
  • The role of Internal Audit (Third Line of Defense) in reviewing the MRG function and model compliance.
  • The legal and regulatory environment for AI in finance (e.g., data privacy, transparency requirements).

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April 13, 2026 - April 17, 2026

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