How a Fortune 500 Bank Built AI Governance in 90 Days

The Challenge

A top-20 US bank was deploying AI across credit decisioning, fraud detection, and customer service automation. With the OCC issuing new guidance on AI risk management and internal audit flagging governance gaps, the bank needed a comprehensive AI governance framework — fast.

The Approach

The SamurAI deployed a three-person team embedded within the bank's AI Center of Excellence. Our approach focused on three parallel workstreams:

1. Model Inventory & Risk Classification — We cataloged 147 AI models across 12 business lines, classifying each by risk tier using the bank's existing enterprise risk taxonomy
2. Policy Development — We drafted AI-specific policies covering model development, validation, deployment, and monitoring — aligned with SR 11-7 and the NIST AI RMF
3. Technical Controls — We implemented automated bias testing, model drift detection, and explainability reporting integrated into the bank's existing MLOps pipeline

The Results

• 90 days from kickoff to board-approved governance framework
• 147 models cataloged and risk-classified
• Zero regulatory findings in the subsequent OCC examination
• 40% reduction in model validation cycle time through automated testing

The SamurAI didn't just help us check a regulatory box. They helped us build a governance capability that actually makes our AI systems better. — Chief Risk Officer