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Managing Family Offices' AI Risk – White Paper
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This paper from a law firm points out that family offices operate in a highly sensitive environment, where confidentiality, discretion and trust are paramount. At the same time, AI introduces a range of new and evolving risks.
The following "Family Office Insights" article, published this month – with the sub-head of "Managing Family Office AI Risk" – comes from the international law firm Squire Patton Boggs. This news service is republishing this article with the firm's permission.
The intersection of AI, cybersecurity and the family office world is one that we have explored several times, such as in the Family Wealth Report Family Office Cybersecurity Forum, held in Manhattan in June. Given the pace of change in AI, wealth managers need to revisit this topic regularly. The editors are pleased to share this content; the usual editorial disclaimers apply regarding outside contributors' content. To contact the editors, email tom.burroughes@wealthbriefing.com and amanda.cheesley@clearviewpublishing.com
AI is rapidly becoming embedded in family office technology infrastructure and increasingly shaping how family offices operate. Across the sector, principals are seeking greater efficiency, improving decision quality and using more effective systems to navigate an increasingly dynamic and complex investment and operational environment.
When appropriately deployed, AI can streamline processes, enhance the synthesis of complex information and improve responsiveness across lean teams. More fundamentally, AI has the potential to strengthen decision-making, particularly in environments where information is fragmented, workflows are distributed and institutional knowledge is not always formally captured.
However, family offices operate in a highly sensitive environment, where confidentiality, discretion and trust are paramount. At the same time, AI introduces a range of new and evolving risks. Threat actors, too, are also beginning to make increasingly sophisticated use of AI to target vulnerable high-value targets. As AI adoption accelerates, the central challenge is therefore no longer whether AI can deliver productivity gains, but how those gains can be realised within a controlled and risk-aligned framework. In short, the use of AI without appropriate governance and guardrails has the potential to become a significant area of strategic risk for family offices.
Key AI-related risks for family offices
The risks presented by AI in the family office context are not
uniform; they will be use-case dependent and may arise across
multiple layers, such as technology, data and information
security, human resources, third-party relationships and
organisational behaviour, among others.
Fundamental risks that we are increasingly observing include:
Model level and operational risks
Systemic risks may be baked into AI models themselves and, given
the lack of transparency in how AI models behave, the risks may
be difficult to detect during routine operations. For example,
where AI models are trained on historical data, biases can be
embedded that produce systematically skewed outputs.
Models can also experience drift, whereby performance degrades as underlying data patterns, model behaviours, market dynamics and regulations evolve. Additionally, staff usage may lead to inadvertent prompt injections. Inputs used from third-party materials, such as emails, could be malicious and lead to misleading outputs or even disclosure of sensitive data.
Hallucinations and automation bias
AI models are known to confidently produce inaccurate information
that is not obviously wrong, but convincingly wrong. The quality
and clarity of such hallucinations can create a tendency to place
undue reliance on them; a phenomenon often described as
"automation bias." 1 This can reduce critical scrutiny,
particularly where outputs align with pre-existing assumptions,
or are produced efficiently relative to traditional methods. In
decision-making contexts, such as investment, this creates a risk
that AI shifts from being a decision-support tool to an implicit
decision driver, without appropriate oversight or challenge.
Data exposure and confidentiality risks
The use of AI tools, particularly externally hosted or publicly
available systems, creates a risk that personal and sensitive
information about families, often spanning generations, may be
disclosed, stored or processed outside the organisation's
control, potentially resulting in breaches of confidentiality,
loss of proprietary information or non-compliance with data
protection requirements. Unlike traditional cybersecurity
incidents, this form of exposure may arise through ordinary use
without a clear breach event, making it more difficult to detect
and manage.
Cybersecurity risks
Family offices face growing exposure to cybersecurity threats as
they manage significant concentration of wealth, sensitive
personal data and complex transactions across multiple entities,
which makes them high-value targets.
Vulnerabilities can also be introduced by third parties who have privileged data about families who expand the attack surface. A single successful breach could result in material financial loss, reputation damage and compromise of highly sensitive data.
AI-enabled fraud and social engineering
AI is increasingly being used to enhance the sophistication of
fraud and social engineering attacks. This includes the
generation of highly convincing written communications, as well
as the use of voice cloning and deep fakes to impersonate trusted
individuals. Family offices can be key targets given the nature
of the data they deal with, the lean structures of the team,
reliance on informal communication channels and the premium
placed on speed and discretion in decision-making. The risk is
not limited to technical compromise, but extends to manipulation
of human behaviour through increasingly credible forms of
impersonation.
Vendor opacity
The use of third party AI tools introduces dependencies on
external systems which often have underlying models, data
practices and operational controls that are not fully
transparent. Limited visibility over the full AI supply chain and
underlying contractual arrangements can create legal, operational
and jurisdictional risks that may not be apparent at the point of
adoption, particularly where sensitive information is involved,
or outputs are relied upon for decision-making.
Regulatory exposure
Although AI-specific regulation, such as the EU AI Act, continues
to evolve, the use of AI is already subject to a wide range of
existing legal and regulatory frameworks in most jurisdictions,
such as data privacy and other regimes governing automated
decision-making, laws prohibiting discriminatory practices and
laws relating to product safety.
Sector-specific regulators, such as the Information Commissioner's Office and the Financial Conduct Authority in the UK, have also published specific guidance on how existing rules can be aligned with the UK government's AI regulatory and policy objectives, and the same trend can be observed in many other jurisdictions.
Inadequate controls over AI usage may therefore trigger exposure under these adjacent regimes, even where no AI-specific rules have been expressly breached.
Organisational and reputational risks
The risks above are multilayered, and their complexity
necessitates a coordinated organisational response, rather than
ad hoc or tool-specific controls. Given the nature of family
office operations, where discretion, trust and long-term
relationships are central, AI failure arising from AI use may
have consequences that extend beyond operational disruption to
include financial loss, legal and regulatory exposure and
reputational harm. These risks are compounded by the threat posed
by external actors who increasingly deploy AI for its
cyber-offence capabilities, as noted above.
Governance response
The multilayered nature of AI-related risk requires a structured
and proportionate governance response that aligns with the
operational realities of the family office. The objective is not
to introduce complexity or reinvent the wheel. It is to
establish clear parameters within which AI can be used
effectively and responsibly, as well as to introduce these within
a governance framework that can be effectively and efficiently
adopted by the organisation.
Use-case identification and risk
classification
Family offices should develop a clear understanding of how AI is
being used across the organisation. This can be achieved by
developing and regularly refreshing an inventory of use cases,
which can then be categorised by risk level, for example,
distinguishing between administrative applications and those that
inform investment or strategic decisions. This allows governance
efforts to be tailored to the use-cases and focused on where risk
is greatest.
Understand the AI systems you have deployed
Because of the inherent limitations of AI systems, it is
important that family offices have a baseline understanding of
how these systems operate, the type of models that have been
procured (e.g. narrow, generative or agentic), the capabilities
of the underlying model enabling the use-case, the intended uses
of the models that have been procured and whether they are being
deployed in alignment with the intended uses, and so on. Where
available, it is good practice to refer to dataset nutrition
labels, system documentation (such as system or model cards), and
evaluation results, as they can provide insight into
explainability or interpretation, capabilities, expected
behaviour, limitations and risks, enabling more informed and
disciplined use.
AI policies, data governance and regulatory
compliance
A foundational step is implementing clear internal AI
governance frameworks, setting out permitted and restricted uses
of AI tools and establishing guardrails for handling sensitive
data. This should be closely aligned with existing data
governance practices, ensuring that confidentiality, privacy and
data protection considerations are consistently applied in an AI
context. Such policies must also be aligned with any AI-specific
and existing legislation in parallel domains.
Human oversight and accountability
AI should not be a substitute for judgment, requiring clear lines
of oversight and accountability, particularly in higher-risk use
cases. Family offices should ensure that AI-assisted outputs are
subject to appropriate human review, that the role of AI in
decision-making is understood and, where material, documented and
that ultimate responsibility remains clearly attributable to
identified individuals or functions.
Supply chain mapping
To the extent possible, family offices should implement a
proportionate approach to vendor oversight, based on
understanding the risks being transferred. This includes
undertaking targeted due diligence on AI providers and reviewing
core contractual terms to ensure, for example, that content
submitted to AI systems remains the organisation's and is not
used in outputs provided by the system to other users. In
addition, mapping key dependencies within the AI supply chain can
provide greater visibility over indirect exposures and support
more informed risk-management.
AI literacy and awareness
Family office teams should have a practical understanding of how
AI systems operate. They must be trained on limitations and the
risks of AI, particularly in relation to hallucinations,
potential bias, AI-enabled cyber threats and human behavioural
manipulation risk, as well as the creation of security
vulnerabilities through untrusted or malicious inputs. This does
not require technical expertise, but rather sufficient awareness
to ensure that inputs are reviewed and outputs treated with
appropriate scrutiny, that suspicious or anomalous behaviour is
recognised and that AI tools are used in a controlled and
security-conscious manner as part of day-to-day workflows.
Conclusion
AI presents a clear opportunity for family offices to enhance
efficiency, strengthen decision-making and modernise operational
processes. However, as its use becomes more embedded within core
activities and operational infrastructure, the associated risks,
ranging from data exposure and model limitations to external
dependencies and AI-enabled threats, become correspondingly more
complex and interconnected.
The challenge for family offices is to ensure that AI is integrated in a manner that is consistent with their existing risk profile, governance standards and the high degree of trust and confidentiality that underpins their operations. This requires a shift from viewing AI as a standalone tool to recognising it as part of the broader operational and decision-making framework of the organisation. A proportionate, well-structured governance approach enables family offices to capture the benefits of AI while maintaining discipline and oversight.
The lawyers cited on this paper are David Naylor, partner, and Uzma Chaudhry, associate. Both are in London.