CM for AI Vendors: Why Annual Reviews Aren't Enough

Three Pillars of AI Continuous Monitoring

Cyber Continuous Monitoring uses vendor risk-rating tools and threat-intelligence software to identify emerging risks in near real time. These tools scan vendor network perimeters for public-facing vulnerabilities, botnet infections, open ports, misconfigured DNS, and other indicators of compromise. When evaluating these tools for AI-specific risk, explicitly ask the software vendor whether their platform identifies AI-related threats: many are adding this capability. Focus on specific alerts and findings rather than composite scores, which often obscure more than they reveal.

Due Diligence Questionnaires remain valuable for assessing AI risk, but they need to be right-sized. Rather than sending hundreds of questions to all vendors, tailor questionnaires to risk level. Low-risk vendors receive minimal AI questions; high-risk vendors receive comprehensive assessments aligned to your chosen AI risk framework. The cadence of questionnaire reviews should be defined in governance documentation and followed consistently.

Physical validations are the gold standard. The difference between a questionnaire and a physical validation is like asking your kids if their room is clean versus going to check for yourself. For critical vendors, those whose failure would materially impact your operations, physical validations (on-site or virtual) are essential. The goal isn't to interrogate the vendor with yes/no questions but to have substantive conversations about their security posture and to observe evidence of their governance in practice.

The Six-Month Rule

Given the pace of AI development and regulatory change, AI-related aspects of your TPRM program should be reviewed every six months. This is more frequent than the typical annual TPRM review cycle, but given how rapidly the AI risk landscape is evolving, it's the appropriate cadence.

Coming up next: Physical vendor validations for AI: what to look for and how to conduct them.