AI won’t take down your company by itself. But the way you ignore it just might. In 2023, Samsung engineers accidentally leaked proprietary source code by pasting it into ChatGPT. Around the same time, researchers showed how Microsoft’s Copilot could be tricked with a simple prompt injection to reveal hidden instructions. These aren’t fringe cases — they’re signs of a deeper reality: AI has already changed the threat model, but most organizations are still securing yesterday’s risks. The attack surface is no longer just your infrastructure, it’s your behavior. And unless leaders update their approach, they’ll discover too late that the governance gap, not the technology itself, is what exposes them. The New AI Threat Model Traditional cybersecurity was designed to protect networks, devices, and identities. With AI, the attack surface shifts: it’s no longer just about systems, it’s about decision-making. AI introduces unique risks: Attack surface expansion: Model poisoning, prompt injection, adversarial inputs, and training data leakage all compromise the integrity of AI. You’re not just securing servers, you’re securing logic.Shadow AI adoption: Employees freely paste sensitive data into unvetted AI tools, with no clarity on where it’s stored or how it’s reused. This is shadow IT on steroids.Skill and tooling mismatch: Most security teams still think in terms of endpoints and firewalls, but AI risk lives in pipelines, weights, inference layers, and feedback loops.Opaque vendor ecosystems: Third-party AI providers are often black boxes. If their model updates tomorrow, your risk posture changes instantly, and you may never know. Attack surface expansion: Model poisoning, prompt injection, adversarial inputs, and training data leakage all compromise the integrity of AI. You’re not just securing servers, you’re securing logic. Attack surface expansion: Shadow AI adoption: Employees freely paste sensitive data into unvetted AI tools, with no clarity on where it’s stored or how it’s reused. This is shadow IT on steroids. Shadow AI adoption: Skill and tooling mismatch: Most security teams still think in terms of endpoints and firewalls, but AI risk lives in pipelines, weights, inference layers, and feedback loops. Skill and tooling mismatch: Opaque vendor ecosystems: Third-party AI providers are often black boxes. If their model updates tomorrow, your risk posture changes instantly, and you may never know. Opaque vendor ecosystems: The result: security assumes AI is someone else’s problem, AI teams assume security will catch up later. That handoff is where organizations are most vulnerable. Data Governance & Compliance: Yesterday’s Language, Tomorrow’s Technology Regulations like GDPR, FDA, SEC, HIPAA were built for static systems, not self-learning models. Companies are left trying to apply yesterday’s compliance language to tomorrow’s technology. This is where NIST stepped in. Its AI Risk Management Framework (RMF), launched in 2023, is quickly becoming the industry’s scaffolding. It’s voluntary, but forward-looking organizations are using it to prove trustworthiness before regulators force the issue. AI Risk Management Framework (RMF) And NIST isn’t just principles on paper , it’s practical tools: Cybersecurity overlays that extend traditional NIST 800-53 controls to AI-specific risks like model poisoning or prompt manipulation.An updated Privacy Framework covering inference risk and secondary use of AI-generated data.Playbooks and sector profiles that help CISOs, developers, and compliance teams finally speak the same language. Cybersecurity overlays that extend traditional NIST 800-53 controls to AI-specific risks like model poisoning or prompt manipulation. Cybersecurity overlays An updated Privacy Framework covering inference risk and secondary use of AI-generated data. An updated Privacy Framework Playbooks and sector profiles that help CISOs, developers, and compliance teams finally speak the same language. Playbooks and sector profiles In plain English: NIST is giving you the rulebook before the refs even show up. Early adopters will be ahead of regulators, not scrambling behind them. Implementation: Where Startups Should Begin For startups, governance usually feels like something you “add later.” That’s a costly mistake. Retrofits are 10x more expensive than building guardrails up front. The first step isn’t technical, it’s clarity. Answer three questions before plugging in a single AI tool: What data can we use, and under what conditions? Even a one-page Slack guideline, public, internal, confidential, regulated — prevents accidental breaches.Who owns AI risk? One accountable leader (CTO, COO, or founder) must be named. Without ownership, AI projects quickly turn into shadow AI.How do we evaluate vendors? Most risk comes from third-party tools. Ask: Where does data go? Is it used for retraining? Can we audit or opt out? What data can we use, and under what conditions? Even a one-page Slack guideline, public, internal, confidential, regulated — prevents accidental breaches. What data can we use, and under what conditions? Who owns AI risk? One accountable leader (CTO, COO, or founder) must be named. Without ownership, AI projects quickly turn into shadow AI. Who owns AI risk? How do we evaluate vendors? Most risk comes from third-party tools. Ask: Where does data go? Is it used for retraining? Can we audit or opt out? How do we evaluate vendors? And the technical side doesn’t require enterprise budgets: tools like Gandalf simulates prompt attacks, adversarial inputs test model resilience, and basic logging ensures traceability. Gandalf Early governance isn’t expensive, it’s discipline. And the startups that set expectations early actually innovate faster because they don’t waste time rebuilding under pressure. Future Outlook: Governance as a Growth Strategy In the next few years, we’ll see convergence on outcomes, but divergence on paths: The EU is going prescriptive: high-risk classifications, strict documentation, detailed rules.The US is moving through procurement and audits: less central law, more sector-driven enforcement. The EU is going prescriptive: high-risk classifications, strict documentation, detailed rules. EU The US is moving through procurement and audits: less central law, more sector-driven enforcement. US Different approaches, same expectation: show your governance. And here’s the shift leaders need to internalize: compliance isn’t a drag on innovation, it’s what enables it. Risk-tier governance prevents over-engineering low-risk use cases.Showing progress, not perfection satisfies regulators and builds customer trust.Turning governance into a feature (“Our AI is explainable, auditable, and monitored”) transforms compliance from red tape into competitive advantage. Risk-tier governance prevents over-engineering low-risk use cases. Risk-tier governance Showing progress, not perfection satisfies regulators and builds customer trust. Showing progress, not perfection Turning governance into a feature (“Our AI is explainable, auditable, and monitored”) transforms compliance from red tape into competitive advantage. Turning governance into a feature The future won’t belong to companies that deploy AI the fastest. It will belong to companies that deploy AI with control, because that’s who regulators, investors, and customers will trust. AI is moving faster than regulation, but governance doesn’t have to be a bottleneck. Done right, it’s a growth strategy. The question for leaders isn’t “How do we comply at the end?” It’s “How do we embed accountability from the start?” Because in the AI era, trust isn’t just a value, it’s the ultimate competitive advantage. “How do we comply at the end?” “How do we embed accountability from the start?”