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The AI black box problem: How financial organizations can ensure AI explainability and transparency

Key takeaways:
  • Black box AI systems are those that cannot explain how they make decisions. This is a particular problem in the financial world, where AI is already widely used for credit scoring or fraud detection and prevention. Every decision made by such systems needs to be explainable.
    • Credit scoring – for example, what is the reason a certain client was denied a loan? Was it due to low income, poor credit history, or something else?
    • Fraud detection and prevention – for example, why was a specific transaction blocked?
  • Besides helping build trust among all stakeholders, AI explainability is also required by GDPR, which, in Article 22, states that every decision made by an AI system must be explainable.
  • The EU AI Act also places strong emphasis on AI explainability, with the goal of making AI systems transparent, explainable, ethical, and fair.
  • Financial institutions should prioritize explainability of the AI systems they use. This can be done in several ways:
    • By integrating a culture of AI explainability from the start, if developing AI systems in-house.
    • Through detailed assessments of AI vendors, when integrating third-party models. TrustPath’s AI Vendor Assessment Framework can help with this.
    • By continuously monitoring AI vendors through an AI use case registry – another feature included in the TrustPath platform.
The AI black box problem: How financial organizations can ensure AI explainability and transparency

Imagine the following situation: you’ve gained access to a system that can predict stock price movements, warn you in time about price drops, and suggest when to sell. Sounds great, right? We agree. But what if you have no idea how the system actually comes to those results, and you’re gambling with your own money? Not so great, right? These kinds of systems are what we call the AI black box problem – an algorithm that gives a certain result without anyone knowing the logic it followed to get there.

You’re probably wondering, why is that a problem? Well, in highly regulated industries like telecom or finance, where the stakes are very high, decisions need to be explainable. Clients, regulators, and all other involved parties want to know WHAT is behind the decision made by the AI system. Without explainability, using AI is, simply put, like driving a car blindfolded. We’ve already written about this in our article “Navigating compliance risk: Leveraging AI governance tools for seamless management.

So, how do we open the mysterious black box and shed light on how AI systems make decisions? That’s exactly what we’ll explore in this blog post, where we’ll explain why solving this problem is so important – especially if you work in the financial industry.

Why Should AI Explainability Be the MVP of Regulated Industries?

Now that we know why AI black box systems are not the best choice for your organization, let’s explain why working on AI explainability should be your most valuable product.

In regulated industries like finance, telecom, or healthcare, explainability is not just a nice-to-have – it’s a must-have. Think about it and ask yourself – would you trust an AI system that automatically approves your loan or one that diagnoses your health condition, without giving you a clear view into the process and how the decision was made? We doubt it.

Regulations like the EU AI Act and GDPR require that decisions made by AI systems are transparent. For example, under Article 22, the GDPR gives individuals the right to an explanation of automated decisions that affect them. If an AI system can’t provide that, not only are you violating regulations, but you’re also actively inviting legal trouble.

Legal issues aside, explainability builds trust. When customers understand how AI works, they are more likely to accept it, use it, and eventually recommend it to others.

Note: AI explainability is not the same as AI transparency. We wrote about this in our article “AI transparency vs. AI explainability: Where does the difference lie?” so make sure to check it out for a better understanding.

The Danger of Black Box AI Systems in the Financial Industry

Let’s now take a closer look at the risks that black box AI systems bring to finance. Opaque algorithms in finance can easily reject clients for loans or credit without giving a clear explanation of why the decision was made. Or even worse, such systems can unintentionally discriminate against someone based on demographic characteristics or geographic location. Does that sound like a problem? – It definitely is.

Black box AI systems in finance (and other industries) can lead to:

  • financial damage from lawsuits filed by clients of banks and other financial institutions
  • legal trouble with regulators
  • reputational damage depending on the level of the issue

It’s easy to see that AI black box models in finance are not just undesirable – they should be seen as a high-level threat that even large, well-established institutions like banks and other financial organizations cannot afford.

But are explainable AI systems accurate enough? That’s what we’ll discuss in the next section.

AI Explainability vs. Accuracy: Can You Have Both?

These days, we often hear that highly explainable AI systems are usually inaccurate – but is that really true? Absolutely not!

While it may be true that some very complex AI systems, like deep neural networks, are harder to interpret and explain, there’s always a way to find a balance between explainability and accuracy. Hybrid AI models, for example, combine simpler, more interpretable algorithms with complex ones to offer the best of both worlds.

So we can say that the key is choosing the right model for the right problem. In regulated industries like finance or telecom, explainability of AI models should definitely be prioritized. Why? Because, in the end, it’s better to have a slightly less accurate AI system that is fully explainable than a black box model that puts your entire business on thin ice, with risks for your clients, investors, or regulators. Wouldn’t you agree?

Below, we’ll list some examples where we believe AI should be fully explainable in the financial industry.

Explainability in Finance: Show Me the Money, but Show Me How!

As we’ve already mentioned, the financial industry is one of the most regulated industries in the world, along with telecom and healthcare – and for a good reason: money. When money is involved, explainability and transparency are non-negotiable.

Let’s take two examples:

  1. Loan approval for bank clients – if an AI system is performing credit scoring to decide whether a person can get a loan, and it decides to deny it, the AI must explain why. Was it because of a poor credit history? Was it due to their income level? Or maybe because of the overall economic situation in the financial or lending market?
  2. Fraud detection and prevention – as we’ve mentioned in other articles: where there’s money, there’s fraud. Banks, as huge institutions, process billions of transactions every day. Every transaction carries a certain level of risk, and as we wrote in our article AI in financial industry: How banks and insurers can deploy AI without regulatory risks, banks often use AI to detect and prevent fraud. However, if the AI blocks a transaction, it needs to give a reason – why was this transaction flagged? What parameters led it to believe it was fraud and make the decision to block it?

As we can see from both examples above – in each case, AI is making an autonomous decision. Without a clear explanation, everyone involved may think a mistake was made and will have to step in manually, wasting valuable time. But if the AI system clearly explains how it reached that decision, it will help financial institutions better understand the situation, act faster, and maintain better relationships with everyone involved.

The Role of the EU AI Act in AI Explainability in the Financial Industry

As we’ve written before, the EU AI Act is a game changer for several reasons. The first is, of course, that it’s the first comprehensive regulation that governs the development, deployment, and use of AI systems. The second reason is that it doesn’t treat all AI systems the same – it classifies them based on the level of risk they pose to users. The third reason, and the most important for this article, is that it aims to bring transparency into AI systems, build trust, and ensure alignment with ethical principles.

You can read more about the EU AI Act in our guide “EU AI Act guide” here.

When it comes to the EU AI Act, the situation is very clear. Systems classified as high-risk AI – for example, an AI system used for credit scoring in the financial industry – must meet the strictest requirements. These include creating detailed technical documentation, listing the datasets and training data used, and explaining how the system makes decisions – all with the goal of making the AI system as explainable as possible.

You’ll probably agree that for enterprise-level companies like financial institutions, this is not just a challenge, as it may seem at first – it’s also an opportunity. Why an opportunity? Because by following these rules, they can strengthen their reputation, avoid the risks that come with using AI technology, and stand out from the competition.

Focusing on AI Explainability for a Better Future

AI black box models probably won’t disappear from the market anytime soon – they’ll likely be around for a long time, despite regulations. However, that doesn’t mean a company should do nothing, because every such model can seriously threaten the operations of your financial organization.

So how can banks and other financial institutions protect themselves from black box models entering their business? There are several ways:

  • Integrate a culture of explainability from the very beginning of AI model development, if the AI model is being built in-house. This means making AI explainability a core principle during development – one that everyone involved, from product managers to developers, must follow.
  • Conduct a thorough assessment of AI vendors, if you’re buying a pre-built AI model to integrate into your operations. As we’ve already written, under the EU AI Act, if your AI vendors are not compliant, you are the one held responsible and can be fined. Still, manually checking each vendor isn’t a realistic option for many reasons, which we discussed in our article “Automation for the win: Why manual AI vendor checks are setting enterprises up for failure.” That’s why automating these assessments is the best option – and this is where TrustPath can help with its AI Vendor Assessment Framework.
  • Create an AI use case registry so you always have full control over all AI vendors being used across teams in your organization. This is also something TrustPath can help with, as we’ve built a registry that lets you track AI vendors and all updates related to them.

To wrap it up – AI explainability is the only right path forward, because it protects your business from AI-related risks that can impact your operations, finances, and reputation.

If you want to learn more about how we can help you maximize AI explainability, contact us or schedule a demo.

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