AI use-case risk assessment

Worked example: Autonomous loan approval (Australia) · ARA-261031-D7361A · 2026-10-31 06:37:15 UTC · Agentic Risk Analyst v3.2.1 · Worked example: prepared in advance, not generated live

EXECUTIVE DECISION
APPROVE WITH CONDITIONS
Inherent High → residual Medium

Scenario

An Australian retail bank wants to deploy an autonomous AI agent that approves personal loans up to AUD 50,000 using customer transaction history, credit bureau data and open banking data. No human review is planned for approvals under AUD 30,000. The bank intends to use a third-party foundation model via API. Decisions will be delivered to customers in-app within 30 seconds.

Executive narrative

Proceed only with a human gate for declines and larger loans, validated fairness and affordability, and updated transparency. Full automation of declines is not supported.

Top risks

  • Unfair or discriminatory credit outcomes
  • Unsuitable loans approved
  • Automated decisions without required transparency

Conditions

  • Human review of all declines and approvals above AUD 30,000
  • Fairness and affordability testing before go-live
  • Privacy policy updated for APP 1.7 to 1.9 before 10 December 2026

Remediation plan

HorizonIDActionOwnerPriority
0-30 daysA-01Design the human review step and reason codesHead of CreditCritical
30-90 daysA-02Run fairness and affordability validationModel RiskHigh
30-90 daysA-03Update privacy policy and noticesPrivacy OfficerHigh
90+ daysA-04Set up monthly drift and fairness monitoringModel RiskMedium

Risk register

IDRiskLIInherent
R-01Unfair or discriminatory credit outcomesPossibleMajorHigh
R-02Unsuitable loans approvedPossibleMajorHigh
R-03Automated decisions without required transparencyLikelyModerateHigh
R-04Foundation model change or outagePossibleModerateMedium
R-05Drift after deploymentLikelyModerateHigh

Regulatory findings

Evidence status: model knowledge only; verify against source texts.

RegulationApplicabilityWhy it matters
National Consumer Credit Protection Act 2009 (responsible lending) (Australia)applicablePersonal loans to consumers are regulated credit.
Privacy Act 1988 (APPs, including APP 1.7 to 1.9) (Australia)applicablePersonal and credit information drives automated decisions.
APRA CPS 230 Operational Risk Management (Australia)applicableThe bank is APRA-regulated and relies on a third-party model provider.
Anti-discrimination legislation (Commonwealth and state) (Australia)potentially applicableCredit decisions must not discriminate on protected attributes.

Security threats

IDThreatInherentMITRE
T-01Adversarial manipulation of application dataHighMITRE ATLAS AML.T0043
T-02Credential compromise of the model APIMediumMITRE ATT&CK T1552

Controls and residual risk

IDControlPriorityAddresses
C-01Human review of declines and loans above AUD 30,000ImmediateR-01, R-02
C-02Fairness and affordability testing before release and monthlyImmediateR-01, R-02, R-05
C-03Automated-decision transparencyNear-termR-03
C-04Model change control and fallbackNear-termR-04, R-05
RiskInherentResidualJustification
R-01 Unfair or discriminatory credit outcomesHighMediumHuman review and testing catch most unfair outcomes.
R-02 Unsuitable loans approvedHighMediumAffordability testing and review of large loans.
R-03 Automated decisions without required transparencyHighLowPolicy and reasons address the obligation.
R-04 Foundation model change or outageMediumLowVersion pinning and fallback.
R-05 Drift after deploymentHighMediumMonthly monitoring.

Decision support only, not legal or regulatory advice. AI-generated ratings and citations must be reviewed by a qualified person before they are relied on.