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AAT-10.1: AI & Autonomous Technologies Risk Mapping

AAT 9 — Critical Identify

Mechanisms exist to identify Artificial Intelligence (AI) and Autonomous Technologies (AAT) in use and map those components to potential legal risks, including statutory and regulatory compliance requirements.

Renumbered: Formerly AAT-02.1 in SCF 2025.4.

Code reused: In SCF 2025.4 and earlier, AAT-10.1 was AI TEVV Trustworthiness Assessment. That control is now AAT-28.1.

Control Question: Does the organization identify Artificial Intelligence (AI) and Autonomous Technologies (AAT) in use and map those components to potential legal risks, including statutory and regulatory compliance requirements?

General (4)
Framework Mapping Values
ISO 42001 2023 6.1.1 8.2 A.5.3 A.5.4 A.5.5
MPA Content Security Program 5.3.1 OR-5.0
NIST AI 100-1 (AI RMF) 1.0 MAP 4.1
NIST AI 600-1 GV-1.3-005 GV-4.1-002 GV-4.2-002 MP-1.1-004 MAP 4.1
EMEA (1)
Framework Mapping Values
EMEA EU AI Act Article 9.1

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

Artificial Intelligence and Autonomous Technology (AAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with AAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ AAT-related processes are expected to follow the organization's existing processes (e.g., incident response, asset management, change control and risk assessments). ▪ No formal Governance, Risk & Compliance (GRC) team exists to provide AAT oversight, where the Chief Information Officer (CIO), or similar function, governs technology decisions what is acceptable for AAT within the organization.

Level 2 — Planned & Tracked

Artificial Intelligence and Autonomous Technology (AAT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AAT domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with AAT domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Artificial Intelligence (AI)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 — Well Defined

Artificial Intelligence and Autonomous Technology (AAT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AAT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AAT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to identify AAT in use and map those components to potential legal risks, including statutory and regulatory compliance requirements.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. AAT-10.1_A01 a risk catalog of Artificial Intelligence (AI) and Autonomous Technologies (AAT)-specific risks is documented.
  2. AAT-10.1_A02 a compliance catalog of Artificial Intelligence (AI) and Autonomous Technologies (AAT)-specific laws, regulations and contractual obligations is documented.
  3. AAT-10.1_A03 the organization maps its risk catalog to its compliance catalog for Artificial Intelligence (AI) and Autonomous Technologies (AAT).

Technology Recommendations

Micro/Small

  • Basic AI risk assessment (documented risks per AI tool)
  • AI governance program
  • NIST AI RMF Map function reference

Small

  • AI risk assessment for each deployed AI system
  • AI governance program
  • NIST AI RMF Map function implementation

Medium

  • Formal AI risk mapping process aligned to NIST AI RMF
  • AI risk register maintained in GRC platform
  • MITRE ATLAS framework reference for adversarial AI risks

Large

  • Enterprise AI risk mapping integrated with organizational risk register
  • NIST AI RMF Map function with quantified risk scores
  • MITRE ATLAS framework integration
  • AI risk dashboards for management reporting

Enterprise

  • Enterprise AI risk mapping program integrated with GRC and ERM
  • NIST AI RMF Map function at enterprise scale
  • Automated AI risk scoring and continuous monitoring
  • MITRE ATLAS-based adversarial AI risk scenarios

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