The financial service industry is filled with possibilities brought by artificial intelligence (AI), including algorithmic trading, robo-advisory, fraud detection, and credit scoring. But the proliferation of AI raises ethical and regulatory issues, such as bias, opacity, and systemic risk. This paper qualitatively compares AI governance models for finance across five major jurisdictions (EU, US, UK, Singapore, and India). These jurisdictions are united in their objectives of enhancing responsible innovation, protecting consumers, and ensuring transparency, but their regulatory approaches range widely in terms of scope, legal effect, and ethical emphasis. The EU is at the vanguard through its AI Act, which employs a precautionary and rule-driven approach, imposing strict obligations on high-risk uses. By contrast, the US uses a sector-specific, principles-based approach based on existing financial sector regulation and voluntary frameworks, including the NIST AI Risk Management Framework. Both the UK and Singapore have principles-based approaches which promote transparent, accountable, and innovative models based on fluid models, for instance the FEAT framework. India: As an emerging fintech leader, India is building its own balanced model under RBI’s FREE-AI initiative, based on global best practices. The article constructs a systemic comparison chart on AI regulation, enforcement institution, financial AI application, and AI ethics of the codified rules. Thematic analysis identifies key dimensions (explained-by, fairness, accountability, standardization potential). The study adds to the increasing policy conversation on regulating AI by providing policy guidelines which highlights dynamic governance, international collaboration, and integration of ethics throughout the AI lifecycle in finance.

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Mapping AI Governance Models in Finance: A Cross-Country Comparative Study

  • Ravi Baijulal Bhandari,
  • Neha Ramteke,
  • Harshal Anil Salunkhe,
  • Abhishek Raidas,
  • Rajkumar Kankariya,
  • Khushali Oza

摘要

The financial service industry is filled with possibilities brought by artificial intelligence (AI), including algorithmic trading, robo-advisory, fraud detection, and credit scoring. But the proliferation of AI raises ethical and regulatory issues, such as bias, opacity, and systemic risk. This paper qualitatively compares AI governance models for finance across five major jurisdictions (EU, US, UK, Singapore, and India). These jurisdictions are united in their objectives of enhancing responsible innovation, protecting consumers, and ensuring transparency, but their regulatory approaches range widely in terms of scope, legal effect, and ethical emphasis. The EU is at the vanguard through its AI Act, which employs a precautionary and rule-driven approach, imposing strict obligations on high-risk uses. By contrast, the US uses a sector-specific, principles-based approach based on existing financial sector regulation and voluntary frameworks, including the NIST AI Risk Management Framework. Both the UK and Singapore have principles-based approaches which promote transparent, accountable, and innovative models based on fluid models, for instance the FEAT framework. India: As an emerging fintech leader, India is building its own balanced model under RBI’s FREE-AI initiative, based on global best practices. The article constructs a systemic comparison chart on AI regulation, enforcement institution, financial AI application, and AI ethics of the codified rules. Thematic analysis identifies key dimensions (explained-by, fairness, accountability, standardization potential). The study adds to the increasing policy conversation on regulating AI by providing policy guidelines which highlights dynamic governance, international collaboration, and integration of ethics throughout the AI lifecycle in finance.