Questions

Which banks explain how they control AI?

87 of 270 banks (32%) explain in their 2025 annual report how AI is controlled, for example through a committee, a policy or model risk management.

The banks

• Bank of Hawaii Corp
  HI · Mid-size bank ($1B to $50B)

  in 2025 we rolled out three training modules for employees to complete in order to gain access to our artificial intelligence (“AI”) tool Microsoft Co-Pilot.

  Using AI nowRead it in the report
• Capital Bancorp Inc
  MD · Mid-size bank ($1B to $50B)

  Capital Bank uses data analytics, including AI and proprietary models, throughout the OpenSky™ customer lifecycle to support fraud prevention and credit decisioning.

  Using AI nowRead it in the report
• Fifth Third Bancorp
  OH · Large bank ($50B and above)

  Fifth Third launched a comprehensive platform designed to deliver leadership development content and experiences for leaders at all levels. Several new development offerings were launched, including generative Artificial Intelligence (“AI”) training

  Using AI nowRead it in the report
• First Financial Corp
  IN · Mid-size bank ($1B to $50B)

  The Corporation implemented a form of AI with its intelligent digital assistant, Gabby, available through the Bank’s website.

  Sees AI as a riskRead it in the report
• Princeton Bancorp, Inc.
  PA · Mid-size bank ($1B to $50B)

  These include Sophos for advanced cybersecurity threat detection and response, Verafin for fraud detection and AML compliance, the Glia Chatbot for enhancing customer service interactions, and CATO Networks for AI-driven network security and optimization.

  Using AI nowRead it in the report
• U.S. Bancorp
  MN · Large bank ($50B and above)

  The Company also launched an “AI Essentials Channel” on Skills Academy, which is designed to help team members build skills in effectively using Company-approved artificial intelligence tools in their daily work.

  Using AI nowRead it in the report
• Ally Financial Inc.
  MI · Large bank ($50B and above)

  advancing technology that powers dealer and consumer centric products and services leveraging our ongoing investment in data and AI

  General statement about AIRead it in the report
• Amalgamated Financial Corp.
  NY · Mid-size bank ($1B to $50B)

  The NYDFS's requirement that banks maintain a comprehensive data lineage for AI models to prove they are not inadvertently using proxies for protected classes

  Sees AI as a riskRead it in the report
• American Express Co
  NY · Large bank ($50B and above)

  We have established, and continue to maintain, policies and a governance framework to comply with applicable laws and requirements in these areas, meet evolving customer and industry expectations and support and enable business innovation and growth

  Explains how AI is controlledRead it in the report
• Ameris Bancorp
  GA · Mid-size bank ($1B to $50B)

  Our adoption of artificial intelligence, including generative artificial intelligence, machine learning and similar tools and technologies that collect, aggregate, analyze or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency

  Sees AI as a riskRead it in the report
• Avidbank Holdings, Inc.
  CA · Mid-size bank ($1B to $50B)

  we currently use a software product with AI technology to enhance our fraud detection capabilities for our clients’ banking activity

  Using AI nowRead it in the report
• Bank of America Corp
  NC · Large bank ($50B and above)

  Under our Enterprise Model Risk Policy, Model Risk Management is required to perform end-to-end model oversight, including independent validation before initial use, implementation monitoring, ongoing monitoring reviews through outcomes analysis and benchmarking, and periodic revalidation.

  Explains how AI is controlledRead it in the report
• Bank of New York Mellon Corp
  NY · Large bank ($50B and above)

  We also consider data-related risks in the execution of our business objectives and processes, including the development of new products and services, including artificial intelligence applications.

  Explains how AI is controlledRead it in the report
• Bankwell Financial Group, Inc.
  CT · Mid-size bank ($1B to $50B)

  our current and potential future use of AI to support loan origination processes may introduce additional risk of inaccurate, incomplete, or misrepresented information

  Sees AI as a riskRead it in the report
• BayCom Corp
  CA · Mid-size bank ($1B to $50B)

  Mitigating these risks requires a robust governance framework, regularly testing and auditing of AI models, and strong human oversight.

  Explains how AI is controlledRead it in the report
• Bok Financial Corp
  OK · Large bank ($50B and above)

  Each initiative is subject to a specific internal governance process designed to assess risks related to data quality, bias, regulatory compliance, and ethical considerations.

  Sees AI as a riskRead it in the report
• Byline Bancorp, Inc.
  IL · Mid-size bank ($1B to $50B)

  address material risks from potential cybersecurity threats, including threats utilizing generative AI, and to facilitate the governance and oversight of cybersecurity risks

  Explains how AI is controlledRead it in the report
• CVB Financial Corp
  CA · Mid-size bank ($1B to $50B)

  We have adopted an AI Policy that establishes a governance framework for developing, deploying, and managing AI and Generative AI (GenAI) solutions and initiatives, including those involving vendors.

  Explains how AI is controlledRead it in the report
• Capital City Bank Group Inc
  FL · Mid-size bank ($1B to $50B)

  associated with assessing the proper operation of AI models, understanding

  Explains how AI is controlledRead it in the report
• Capital One Financial Corp
  VA · Large bank ($50B and above)

  Our risk reporting and risk management, including our business decisions that are based on information gathered through models and AI, depend on the effectiveness of our models and AI.

  Sees AI as a riskRead it in the report
• Chain Bridge Bancorp Inc
  VA · Mid-size bank ($1B to $50B)

  We have incorporated, and may in the future further incorporate, AI technology in certain business processes, services, and products, including technologies that process sensitive financial and/or personal data. We currently rely on AI tools and models provided by third-party vendors

  Using AI nowRead it in the report
• Charles Schwab Corp
  TX · Large bank ($50B and above)

  Schwab manages model risk, including use of artificial intelligence, through use of policies, standards, and controls which evaluate the conceptual and technical soundness of models used by the Company. Prior to the use of any artificial intelligence, we employ procedures which require

  Explains how AI is controlledRead it in the report
• Citigroup Inc
  NY · Large bank ($50B and above)

  overseeing and reviewing information from management regarding Citi’s approach to Generative AI and reviewing reports on technology and data quality-related matters.

  Explains how AI is controlledRead it in the report
• Coastal Financial Corp
  WA · Mid-size bank ($1B to $50B)

  We currently use, and may in the future evaluate or implement, artificial intelligence (“AI”), automation, and similar technologies to support certain internal processes or business functions.

  Using AI nowRead it in the report
• Commercial Bancgroup, Inc.
  TN · Mid-size bank ($1B to $50B)

  Our adoption of AI for limited internal use has increased our efficiency, and we expect to continue to adopt such tools as appropriate. In addition, we expect our third-party vendors and service providers to increasingly develop and incorporate AI into their product offerings

  Sees AI as a riskRead it in the report
• Community Financial System, Inc.
  NY · Mid-size bank ($1B to $50B)

  CFSI maintains enterprise-wide AI and Data Governance frameworks designed to promote the accuracy, privacy, security, and responsible use of data and AI across our operations. Executive oversight is provided by the Management Risk Committee and IT Steering Committee

  Explains how AI is controlledRead it in the report
• ConnectOne Bancorp, Inc.
  NJ · Mid-size bank ($1B to $50B)

  we have policies and governance structures prohibiting our employees from using non-approved generative AI applications or websites on the Company or the Bank’s network or devices

  Explains how AI is controlledRead it in the report
• Customers Bancorp, Inc.
  PA · Mid-size bank ($1B to $50B)

  In 2025, the Bank launched enterprise-wide training covering foundational AI concepts, responsible-use protocols, and real-world applications tailored to business needs. These initiatives have already generated measurable efficiencies and continue to accelerate the integration of AI into core

  Using AI nowRead it in the report
• Dime Commercial Bancshares, Inc.
  NY · Mid-size bank ($1B to $50B)

  Potential AI/ML models, used for credit scoring, fraud detection, customer service, and investment decisions, rely on complex algorithms and vast datasets. Errors, biases, or "hallucinations" (generating false information) in these models, or unexpected system failures, could lead to flawed

  Sees AI as a riskRead it in the report
• Eagle Bancorp Montana, Inc.
  MT · Mid-size bank ($1B to $50B)

  Our adoption of artificial intelligence, including generative artificial intelligence, machine learning and similar tools and technologies that collect, aggregate, analyze or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency

  Sees AI as a riskRead it in the report
• F.N.B. Corporation
  PA · Large bank ($50B and above)

  continually make technological investments to remain competitive in the financial services industry, including the use of AI.

  Using AI nowRead it in the report
• FB Financial Corp
  TN · Mid-size bank ($1B to $50B)

  Our current use of AI is confined to controlled, non‑critical administrative or productivity‑support purposes, such as research assistance, drafting, and data summarization.

  Using AI nowRead it in the report
• Finwise Bancorp
  UT · Small bank (Under $1B)

  While we have policies prohibiting our employees from using non-approved generative AI applications or websites on the Company or the Bank’s network, there can be no assurances that our employees will adhere to these policies

  Sees AI as a riskRead it in the report
• First Bancorp, Inc
  ME · Mid-size bank ($1B to $50B)

  Currently employees have access to generative AI applications for limited productivity and research purposes.

  Using AI nowRead it in the report
• First Busey Corp
  KS · Mid-size bank ($1B to $50B)

  The use of artificial intelligence-powered tools provide additional layers of fraud and threat detection, enabling proactive management.

  Using AI nowRead it in the report
• First Business Financial Services, Inc.
  WI · Mid-size bank ($1B to $50B)

  Provided employees with extensive artificial intelligence tools training to enhance productivity and proficiency, modernize workflows, and improve operational efficiency across the Company.

  Using AI nowRead it in the report
• First Citizens Bancshares Inc
  NC · Large bank ($50B and above)

  We continue to monitor and evaluate statutory and regulatory proposals related to AI regulation and assess their potential impact.

  Explains how AI is controlledRead it in the report
• First Hawaiian, Inc.
  HI · Mid-size bank ($1B to $50B)

  policies for critical security operational functions related to encryption, endpoint protection, vulnerability management, remote access, multifactor authentication, handling confidential information, use of internet, social media, email, artificial intelligence (AI), and wireless devices

  Explains how AI is controlledRead it in the report
• First Horizon Corp
  TN · Large bank ($50B and above)

  New technologies, services, and systems based wholly or in part on artificial intelligence are proliferating within our industry, including at our Company as we are seeking to accelerate both our data capabilities and our responsible use of artificial

  Sees AI as a riskRead it in the report
• First Merchants Corp
  IN · Mid-size bank ($1B to $50B)

  Although the Corporation has established governance, risk management, and control frameworks intended to oversee the use of artificial intelligence, these frameworks may not identify or mitigate all current or emerging risks associated with rapidly evolving technologies.

  Sees AI as a riskRead it in the report
• Five Star Bancorp
  CA · Mid-size bank ($1B to $50B)

  Our adoption of artificial intelligence, including generative artificial intelligence, machine learning, and similar tools and technologies that collect, aggregate, analyze, or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency

  Sees AI as a riskRead it in the report
• Glacier Bancorp, Inc.
  MT · Mid-size bank ($1B to $50B)

  emerging risks from the use of applications that may rely on artificial intelligence

  Sees AI as a riskRead it in the report
• Goldman Sachs Group
  NY · Large bank ($50B and above)

  the Firmwide Artificial Intelligence Risk and Controls Committee, which oversees risks associated with the use of AI, reports to the Firmwide Technology Risk Committee.

  Explains how AI is controlledRead it in the report
• Great Southern Bancorp, Inc.
  MO · Mid-size bank ($1B to $50B)

  Mitigating these risks requires a robust governance framework, regularly testing and auditing of AI models, and strong human oversight.

  Explains how AI is controlledRead it in the report
• HSBC Usa Inc
  NY · Large bank ($50B and above)

  We support leaders and model developers with training that helps them understand and apply our principles on the ethical use of big data and artificial intelligence.

  Explains how AI is controlledRead it in the report
• Hancock Whitney Corp
  MS · Mid-size bank ($1B to $50B)

  Our Board of Directors oversees the Company’s use of Artificial Intelligence (AI). Management has established an AI Working Group, which includes representatives from Legal, Compliance, Risk, and Information Technology.

  Explains how AI is controlledRead it in the report
• Horizon Bancorp Inc
  IN · Mid-size bank ($1B to $50B)

  Our adoption of artificial intelligence, including generative artificial intelligence, machine learning, and similar tools and technologies that collect, aggregate, analyze, or generate data or other materials or content (collectively, “AI”), is limited for internal currently, and we expect to

  Sees AI as a riskRead it in the report
• Huntington Bancshares Inc
  OH · Large bank ($50B and above)

  an Artificial Intelligence Risk Committee

  Explains how AI is controlledRead it in the report
• International Bancshares Corp
  TX · Mid-size bank ($1B to $50B)

  Artificial Intelligence Ethics & Governance Policy, which integrates AI-specific security requirements into our ISSP and incident response processes.

  Explains how AI is controlledRead it in the report
• JPMorgan Chase & Co.
  NY · Large bank ($50B and above)

  A dedicated independent function, Model Risk Governance and Review (“MRGR”), defines and governs the Firm’s policies relating to the management of model risk and risks associated with certain analytical and judgment-based estimations

  Explains how AI is controlledRead it in the report
• Juniata Valley Financial Corp
  PA · Small bank (Under $1B)

  Although the Company does not currently make significant use of artificial intelligence (“AI”), machine learning, or similar advanced data analytics technologies in its operations, the financial services industry is increasingly incorporating AI-enabled tools in areas such as credit underwriting,

  Sees AI as a riskRead it in the report
• Live Oak Bancshares, Inc.
  NC · Mid-size bank ($1B to $50B)

  We continually evaluate and selectively deploy emerging technologies like artificial intelligence (“AI”), sometimes referred to as AI, and machine learning for incorporation in our business.

  Using AI nowRead it in the report
• MUNCY COLUMBIA FINANCIAL Corp
  PA · Mid-size bank ($1B to $50B)

  The Corporation has adopted an AI and Automated Tool Usage Policy to establish guidelines for the responsible, secure, and compliant use of AI systems, automated bots, Application Programming Interfaces (“APIs”), and machine learning technologies within the organization.

  Explains how AI is controlledRead it in the report
• MainStreet Bancshares, Inc.
  VA · Mid-size bank ($1B to $50B)

  We have implemented an AI governance function and risk management framework that includes a risk assessment of internal and vendor AI solutions, due diligence, and controls.

  Explains how AI is controlledRead it in the report
• Midland States Bancorp, Inc.
  IL · Mid-size bank ($1B to $50B)

  This includes development in areas such as generative artificial intelligence, robotic process automation, process improvement, and data-informed decision-making.

  Using AI nowRead it in the report
• Morgan Stanley
  NY · Large bank ($50B and above)

  We continually review our Cybersecurity Program, and make adjustments where appropriate, to address the evolving cybersecurity threat landscape, including threats arising from new technologies, such as generative artificial intelligence

  Explains how AI is controlledRead it in the report
• NBT Bancorp Inc
  NY · Mid-size bank ($1B to $50B)

  The Company’s use of AI currently varies across platforms, with certain third party systems incorporating AI capabilities into routine business operations. As our adoption and internal development of AI enabled tools continues to evolve, we evaluate these technologies through our established

  Sees AI as a riskRead it in the report
• NewtekOne, Inc.
  FL · Mid-size bank ($1B to $50B)

  we leverage software and artificial intelligence (“AI”) to extract, process and exchange information from borrowers and businesses in need of a business or financial solution.

  Using AI nowRead it in the report
• Northern Trust Corp
  IL · Large bank ($50B and above)

  Northern Trust has certain processes and controls in place designed to mitigate the risks associated with the use of AI solutions, including monitoring the development and applicability of such evolving laws and regulations

  Explains how AI is controlledRead it in the report
• OFG Bancorp
  PR · Mid-size bank ($1B to $50B)

  a self-service platform powered by AI that provides real time analytics, insights, recommended actions, and learning tools focused on expectations, recognition, collaboration, and development

  Using AI nowRead it in the report
• OP Bancorp
  CA · Mid-size bank ($1B to $50B)

  Certain of these third‑party service providers may incorporate or rely on artificial intelligence (“AI”), machine learning, automated decision‑making technologies or similar emerging technologies

  Sees AI as a riskRead it in the report
• PNC Financial Services Group
  PA · Large bank ($50B and above)

  There are risks resulting from the extensive use of models, some of which use AI, in our business.

  Sees AI as a riskRead it in the report
• Peoples Bancorp of North Carolina Inc
  NC · Mid-size bank ($1B to $50B)

  We have implemented an AI governance function and risk management framework that includes a risk assessment of internal and vendor AI solutions, due diligence, model validation, and controls.

  Sees AI as a riskRead it in the report
• Raymond James Financial Inc
  FL · Large bank ($50B and above)

  ineffective or inadequate AI development or deployment practices by us or third-party vendors could result in unintended consequences such as AI algorithms that produce inaccurate output or that are based on biased, incomplete, and/or inaccurate datasets

  Sees AI as a riskRead it in the report
• Renasant Corp
  MS · Mid-size bank ($1B to $50B)

  a new back-office process or procedure (each of which may involve the incorporation of AI technologies), the implications to the Company’s information security are required to be considered.

  Explains how AI is controlledRead it in the report
• Republic Bancorp Inc
  KY · Mid-size bank ($1B to $50B)

  The evolving federal “AI Action Plan” and related regulatory initiatives could increase compliance costs, constrain the Company’s use of AI, and expose the Company to new legal, operational, and reputational risks.

  Sees AI as a riskRead it in the report
• Richmond Mutual Bancorporation, Inc.
  IN · Mid-size bank ($1B to $50B)

  Mitigating these risks requires a robust governance framework, regularly testing and auditing of AI models, and strong human oversight.

  Explains how AI is controlledRead it in the report
• S&T Bancorp
  PA · Mid-size bank ($1B to $50B)

  We also depend on third-party vendors and service providers for core systems and specialized tools that may incorporate artificial intelligence functionality. Our ability to manage artificial intelligence related risk is therefore partially dependent on the controls, governance and resilience of

  Sees AI as a riskRead it in the report
• Santander Holdings USA, Inc.
  MA · Large bank ($50B and above)

  We utilize AI and continue to explore additional uses of AI in connection with our businesses, products and services. However, AI solutions, such as those provided by third parties, may expose us to risks including, without limitation, inadequacies in the AI service that results in false or

  Sees AI as a riskRead it in the report
• Sierra Bancorp
  CA · Mid-size bank ($1B to $50B)

  the Company’s deployment of AI at this time is generally limited to fraud detection or prevention; we continue to evaluate whether to implement additional AI tools, or agentic AI, in certain limited capacities

  Using AI nowRead it in the report
• SouthState Bank Corp
  FL · Large bank ($50B and above)

  We have adopted a formal AI Strategy and are making focused investments in AI tools and automation and other technology solutions to improve both our customer facing and back-office services for internal efficiencies

  Testing or planning AIRead it in the report
• State Street Corp
  MA · Large bank ($50B and above)

  All regulatory capital calculation models, including any artificial intelligence and machine learning models, must comply with the model risk management framework and corresponding policies.

  Explains how AI is controlledRead it in the report
• Stock Yards Bancorp, Inc.
  KY · Mid-size bank ($1B to $50B)

  While we have established programs to manage our increasing exposure to AI, including processes for monitoring related risks, managing third party relationships, incident response, as well as employee awareness and education

  Sees AI as a riskRead it in the report
• Synchrony Financial
  CT · Large bank ($50B and above)

  Training topics include social engineering (such as phishing), AI, including AI-related threats, and outbound data sharing.

  Explains how AI is controlledRead it in the report
• Truist Financial Corp
  NC · Large bank ($50B and above)

  Truist’s AI program is foundationally based on the National Institute of Standards and Technology AI Risk Management Framework Core, which provides outcomes and actions that enable dialogue, understanding, and activities to manage AI risks and develop trustworthy AI systems.

  Explains how AI is controlledRead it in the report
• UNIVEST FINANCIAL Corp
  PA · Mid-size bank ($1B to $50B)

  We utilize certain AI/ML models provided by third-party vendors, including models used for credit scoring and fraud detection, and may use other AI/ML models in the future.

  Sees AI as a riskRead it in the report
• Umb Financial Corp
  MO · Large bank ($50B and above)

  The Company has also established a Technology, Operations, Privacy and Security Committee (TOPS) to oversee the business continuity and resilience, corporate security, fraud, information security, privacy, information technology, and third-party risk management (including emerging technology (e.g.,

  Explains how AI is controlledRead it in the report
• Union Bankshares Inc
  VT · Mid-size bank ($1B to $50B)

  We are piloting and selectively using artificial intelligence and machine learning technologies in limited, primarily internal functions, which exposes us to operational, regulatory, and reputational risks that could adversely affect our business.

  Using AI nowRead it in the report
• Unity Bancorp Inc
  NJ · Mid-size bank ($1B to $50B)

  We use, and expect to continue to expand our use of, artificial intelligence and machine learning technologies, including generative artificial intelligence models, in our operations and through third-party vendors.

  Using AI nowRead it in the report
• Valley National Bancorp
  NY · Large bank ($50B and above)

  we have implemented an AI governance, oversight, and strategic facilitation function that includes a risk assessment of internal and vendor AI solutions, due diligence, model validation, and controls, as well as detailed guidelines and policies designed to promote responsible, secure, and ethical

  Explains how AI is controlledRead it in the report
• Wintrust Financial Corp
  IL · Large bank ($50B and above)

  We may selectively incorporate AI technology in certain business processes, fraud detection, services or products, including technologies that process sensitive financial and/or personal data.

  Sees AI as a riskRead it in the report
• Zions Bancorporation, National Association
  UT · Large bank ($50B and above)

  We have implemented a framework for the responsible use and oversight of AI, guided by established policies and standards, and overseen by the Data and AI Governance Committee.

  Explains how AI is controlledRead it in the report
• Banner Corp
  WA · Mid-size bank ($1B to $50B)

  Our current and future uses of Artificial Intelligence (AI) and other emerging technologies may create additional risks.

  Sees AI as a riskRead it in the report
• Home Bancshares Inc
  AR · Mid-size bank ($1B to $50B)

  New and evolving AI use, including generative AI, may make us susceptible to uncertain risks and may require additional investment to develop responsible use frameworks.

  Sees AI as a riskRead it in the report
• Investar Holding Corp
  LA · Mid-size bank ($1B to $50B)

  Our failure to effectively implement new technologies including artificial intelligence could adversely affect our operations and financial condition.

  Sees AI as a riskRead it in the report
• Isabella Bank Corp
  MI · Mid-size bank ($1B to $50B)

  Emerging technologies, such as artificial intelligence, may further increase the risk of a cyber-attack.

  Sees AI as a riskRead it in the report
• Northpointe Bancshares Inc
  MI · Mid-size bank ($1B to $50B)

  including but not limited to artificial intelligence, which may be used by threat actors to perpetuate cyberattacks

  Sees AI as a riskRead it in the report

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Related questions

• Which banks list AI as a risk but do not say how they control it?
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