In addition to working on each of the pillars of a compliance program, we are seeing more companies adopting technology platforms to improve program management. Artificial intelligence (AI), for example, is already used to preselect complaints received through hotlines and monitor suspicious transactions, among other uses. Although AI offers benefits and efficiency gains, it brings new challenges to consider.

One of the most well-known and disseminated program pillars is the organization’s code of conduct. In it, corporate values are translated into expected behaviors, and conduct guidelines are passed to the entire organization. It is a document that should be updated periodically and complemented by relevant policies (e.g., gifts and entertainment, anti-bribery and corruption, conflicts of interest). Another important activity is risk assessment. But how many organizations stopped to think about the impacts of AI on the pillars of the compliance program?

In technology companies, ethical guidelines for software development, machine learning, and AI are present, and they have been the subject of several debates and reflections. AI can be a valuable solution to many problems and a competitive differentiator, but at the same time, there are risks. AI should offer morally defensible decisions and can be affected by biases in the data used for learning. In this way, ethics has always been closely linked with the theme of AI.

The prominence currently received by ChatGPT and other options (e.g., Bard, Runway) happened because the solution is now available to a wider audience. Any professional from any company—any person, really—can make use of AI platforms, which brings the need to regulate using AI in all organizations. This is certainly an opportune time to update the compliance program.