AI systems are increasingly mediating financial decisions and transactions. This brings efficiency but also new risks.

Risks

Unexplainable AI

As Machine Learning models learn and grow on their own through increased training data, they can start to function as complex “black boxes” with decision making processes that are not easily understandable. This can lead to market risk as the usage of these models proliferates and potential bias in decision making based on data that is not accurate, clean, and up-to-date, or that reflect historical biases

Cybersecurity

As financial institutions deploy AI, they face a double-edged sword: AI can enhance cybersecurity (e.g. fraud detection), but it also introduces new cybersecurity vulnerabilities and threat vectors.

Cybersecurity Threat

Lael Brainard, Director of White House National Economic Council (2023-2025)

“As financial institutions increasingly rely on complex algorithms and machine learning, there is a risk that the models may become less interpretable, less auditable, and harder to validate.”

Michael Hsu, Acting Comptroller of the Currency (2021-2025)

“The widespread use of opaque AI models could lead to systemic blind spots in risk management, particularly if many banks rely on similar black-box systems.”

Unexplainable AI

Many advanced AI models (like deep learning networks) do not easily reveal why they made a given decision. In finance, such opaqueness conflicts with the need for accountability and customer understanding.

Insurance: The black-box issue is perhaps most sensitive in insurance underwriting and claims. AI models might set premiums or flag claims with little explanation, potentially hiding bias. This has already led to lawsuits – in 2022, State Farm was sued after a study suggested its claim algorithm discriminated against Black customers (names common among African Americans saw more claim delays)​ (LexisNexis). And in 2023, health insurer Cigna was hit with a class-action alleging an AI system was automatically denying claims without proper human review ​(LexisNexis). These cases highlight how unexplainable AI can translate into real-world harm (unfair denial of coverage or payouts) and legal peril for firms. 

Payments: Even in payments and fraud detection, lack of transparency can cause trouble. Customers whose transactions are blocked or flagged by an AI fraud system often get no clear explanation, which can frustrate users and damage confidence if legitimate activities are mistakenly caught by opaque models.

Financial intermediation (banking/lending): If a loan application is rejected or approved by an AI, the bank should be able to explain the key factors. Yet “nobody can be entirely sure how the AI makes its decisions” in a black-box model​ (LexisNexis). This isn’t just a theoretical concern: it can mask biases and make it hard to contest decisions. A notorious example was the Apple Card controversy in 2019, where an algorithm (allegedly AI-driven) offered significantly lower credit limits to women than men, sparking public outcry about potential bias.

Asset management: Lack of explainability can also be risky in trading and portfolio management. AI-driven investment funds might make rapid-fire trades based on correlations even the developers don’t fully grasp. This can lead to unexpected losses or volatility. From a risk management perspective, banks and funds worry that if an AI model misfires (ex: makes a huge bet based on spurious data patterns), managers may realize it too late because the model’s logic was not transparent. In 2022, the Bank of England cautioned that firms must be able to justify the trade-off if they deploy a more complex, less interpretable model over a simpler, transparent one​ (Skadden).