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This primer format is intended to be an educational tool regarding emerging AI/Fintech innovations. It is not 

intended to state the official policy or position of the Commodity Futures Trading Commission (CFTC), or to limit the 

CFTC’s current or future positions or actions. The CFTC does not endorse the use or effectiveness of any of the 

financial products or technologies in this presentation. 

The CFTC’s jurisdiction over any particular area will depend on specific facts and circumstances. Any examples

included in this Primer are illustrative only and do not indicate a determination by the CFTC or its staff of jurisdiction.
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Contents

Overview of AI

• What is “Artificial Intelligence” or “AI”? 

• Key Catalysts

• Applications of AI in Financial Markets

• Potential Benefits

The Role of the CFTC

• Promote Responsible AI and Innovation 

• Understand Applications of AI for Markets and Participants

• Identify Trends and Impacts

Moving AI Forward

• Risks and Challenges

• Responding to AI

• Key Considerations for AI Development
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Overview of AI and 

Machine Learning 

• What is “Artificial Intelligence” or “AI”? • Key Catalysts • Applications of AI in Financial Markets • Potential Benefits
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What is “Artificial Intelligence” or “AI”? 

“The simulation of intelligent 

behavior in computers.”

- Merriam-Webster 

Machine Learning is: 

“A field of study that 

gives computers the 

ability to learn without 

being explicitly 

programme d.”

– Arthur Samuel, 1959
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Putting AI in Context

For centuries, philosophers and mathematicians have considered the potential of machine-based 

intelligence.

Since the early 20th Century, AI has featured prominently in popular culture and captured human 

imagination. Futurama at the 1939 World’s Fair Exhibits, films and other media featured self-driving cars, 

thinking machines and other AI applications.

In his seminal 1950 paper Computing Machinery and Intelligence, Alan Turing helped lay the groundwork for 

modern AI, positing a test of when machines could be said to think: “A computer would deserve to be called 

intelligent if it could deceive a human into believing that it was human.”

In the 1950s, research on machine intelligence intensified and became more focused. The term “AI” was 

coined by John McCarthy in 1956.

Approaches to AI have evolved. Early calculating machines 

gave rise to “expert systems.”

Subsequent waves of AI have focused on enabling machines 

to acquire new understanding based on experience. 

Such “machine learning” has become a key element of AI.

Current applications of AI vary widely and are growing exponentially. 

Image Source: Military Enigma machine, model “Enigma I,” used during the late 1930s and during the war. 

By Alessandro Nassiri - Museo della Scienza e della Tecnologia "Leonardo da Vinci", CC BY-SA 4.0, April 23, 2012. 

https://commons.wikimedia.org/w/index.php?curid=47910919
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Perspectives on AI

• “Every aspect of learning or other feature of intelligence can, in principle, be so precisely 

described that a machine can be made to simulate it.” 

– Mission statement of the Dartmouth Conference, 1956

• “Artificial intelligence would be the ultimate version of Google. It would understand exactly 

what you wanted, and it would give you the right thing.” 

– Larry Page, Google Co-Founder, 2000 

• “Just as electricity transformed everything almost 100 years ago, today I actually have a hard 

time thinking of an industry that I don’t think AI will transform in the next several years.” 

– Andrew Ng, Professor, Stanford University, 2017
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AI Approaches: Two End Points

Two end points define a continuum of AI research and applications.

GENERAL INTELLIGENCE

• Theme: Machines behaving 

like humans.

• Adaptable to any job. 

Not domain specific.

• Able to perceive and react 

to broad range of contexts.

• The pop culture perception 

of AI.

• Does not presently exist.

• High transferability within 

and between domains.

SPECIALIZED INTELLIGENCE

• Theme: Machines 

exceeding human 

capability at specific tasks.

• Narrow focus. Domain 

specific.

• Task or job focused. 

• Use cases are proliferating.

• Limited transferability 

across domains.

General Intelligence is much more difficult to develop. For the present and foreseeable 

future, efforts are focused on developing use cases for specialized intelligence.

Applications of specialized intelligence are often designed to augment human intelligence 

and capabilities, but not act independently of human oversight.
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Classifying AI: A Taxonomy

AI is a set of technologies and approaches that has evolved over time. 

• Rules-based, hard-coded algorithms.

•Developers provide the machine with a roadmap of anticipated input and directed output.

• Examples: First generation chess-playing machines and “domain expert” programs.

Expert Systems

• Machine learning may take a variety of approaches that include learning algorithms, pattern

recognition, graphical and statistical modeling, and decision trees.

• Examples: Natural language processing, facial recognition, and robotic process automation are each 

applications of machine learning.

Machine Learning

•A type of machine learning in which the machine incorporates context sensitivity and machinedriven pattern discovery. Can make use of reinforcement learning to extract progressively higher 

level features from data and master complex topics in a short time frame.

• Examples: Gaming machines like Alpha Zero, language translation, medical diagnosis, and object 

detection by self-driving vehicles.

Deep Learning
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AI efforts have developed in waves. Now, a convergence of technologies coupled with advances 

in data science, mass adoption, and increased investment is driving AI forward.

Advanced Software

• Open Source Software 

and Libraries that 

focus on and facilitate 

AI (e.g., TensorFlow, 

Python)

• Deep Learning

• Vision, Natural 

Language Processing, 

Robotic Process 

Automation

AI’s Big Bang

Big Data

• Vast troves of 

accessible data

• Internet of Things 

(IoT) (e.g., sensors, 

satellites)

• Cloud storage

Big Compute 

• Greatly increased 

compute power

• Specialized Hardware 

(e.g., applicationspecific integrated 

circuits)

• Cloud computing
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Catalyst - The Rise of Big Data

“In a world where data is coin of the realm... 

Data is becoming the new raw material of business.” 

— The Economist, “Data, Data Everywhere,” Feb 27, 2010 

• With digitization and greater storage capability, 

big data has become ubiquitous.

• Data has proliferated through Internet of Things 

(IoT), sensors, streaming, text, audio, and video 

files.

• The use of cloud storage has massively increased 

the accessibility of large-scale storage and 

processing of big data.

• Data is the raw material that enables new AI 

systems to train.

• Big data fuels AI. AI’s power is analyzing vast 

pools of data to detect patterns and generate 

insights. 
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Catalyst – Big Compute

• Growth of AI – particularly Deep Learning processes – 

requires significant compute power.

• As it has increased access to data, the development of 

cloud storage has facilitated widespread access to high 

powered computing, enabling substantial advances in AI.

• Computing power has grown exponentially, while costs 

have declined.

• AI-tailored hardware solutions such as Programmable 

Systems on a Chip (PSoC) and parallel core architecture 

are being developed.

• Going forward, the advent of quantum computing is 

expected to further expand AI’s potential.

“Now, what used to be thought of as supercomputers are inside smartphones. They cost a 

million times less, are a million times faster, and have a million times as much memory.”

-Richard Mark Soley, Ph.D., Executive Director, Industrial Internet Consortium
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Case Study – Four Hours to Master Chess

Case Study: Playing Games from “Deep Blue” to “Alpha Zero”

• IBM’s Deep Blue supercomputer defeated world grand 

master Gary Kasparov at chess in 1997. Deep Blue began a 

progression of AI game-playing master machines.

• AlphaZero is a recent incarnation that was developed by 

DeepMind, which is now part of Google. Starting from 

scratch, with only the game rules, AlphaZero became expert 

in chess, shogi and go. In each case, the system beat a 

human world champion. 

• In 2016, AlphaZero also beat the world’s top chess-playing 

computer “Stockfish 8” after only four hours of learning.

• Within the domain of each game, the AI system 

demonstrated an ability to learn “context” – which move 

makes sense when – in a way that approximates human 

grand masters.
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AI Applications in the Financial Markets

• Trading (e.g., market intelligence, robo-advisory, sentiment 

analysis, algorithmic trading, smart routing, and transactions)

• Risk Management (e.g., margin and capital requirements, 

trade monitoring, fraud detection)

• Risk Assessments and Hedging 

• Resource Optimization (e.g., energy and computer power)

• RegTech – Applications that enhance or improve compliance 

and oversight activities (e.g., surveillance, reporting)

• Compliance (e.g., identity and customer validation, antimoney laundering, regulatory reporting)

• Books and Records (e.g., automated trade histories from 

voice / text)

• Data Processing and Analytics

• Cybersecurity and Resilience

• Customer Service

Applications of AI to financial markets are wide-ranging.
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Potential Benefits of AI

Mitigate Human Error: AI systems should not 

fatigue, commit computational errors, or make ad 

hoc or subjective judgments.

Economy and Speed: Automation reduces 

transaction times and unnecessary manual 

processes. 

Leverage Crowd Wisdom: AI systems are able to 

identify trends from vast pools of data – 

essentially to discern insights from the crowd.

Productivity and Efficiency: AI systems can 

leverage computational power to increase 

productivity and free humans to focus on higher 

level tasks. 

Improve Human Experience: In numerous work 

and personal contexts, AI has the potential to 

improve human experience.

Facilitate Market-Enhancing Technologies: AI will 

enable new business models far beyond present 

capabilities. 

Inclusion: AI has the potential to counter human 

biases, enabling a more inclusive financial system.

Improve Access: AI can streamline customer 

onboarding and account setup. 

Enhance Regulatory Compliance: AI systems can 

enhance identity, know-your-customer, and antimoney laundering procedures.

Improve Risk Management: AI can help 

individual participants identify and manage risk as 

well as broader systemic risk monitoring and 

mitigation.

Improve Market Integrity: AI can help detect and 

minimize fraud, manipulation, and other illicit 

activity. 
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The Role of the CFTC 

• Promote Responsible AI and Innovation 

• Understand Applications of AI for Markets and Participants

• Identify Trends and Impacts
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Promote Responsible AI and Innovation

“Artificial Intelligence (AI) promises to drive growth of the United 

States economy, enhance our economic and national security, and 

improve our quality of life.... It is the policy of the United States 

Government to sustain and enhance the scientific, technological, and 

economic leadership position of the United States in AI R&D and 

deployment through a coordinated Federal Government strategy, 

the American AI Initiative....” 

Source: “Executive Order on Maintaining American Leadership in Artificial Intelligence,” 

February 11, 2019, available at https://www.whitehouse.gov/presidential-actions/executiveorder-maintaining-american-leadership-artificial-intelligence/
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The CFTC’s Mission and Approach

• The CFTC’s mission is to promote the integrity, resilience, and vibrancy of the U.S.

derivatives markets through sound regulation.

• Applications of AI and related technologies have the potential to enhance our

markets. Accordingly, the CFTC proactively engages with relevant stakeholders and

seeks to promote promising new technologies.

• Dedicated Fintech Stakeholder: LabCFTC

• Maintain open door with innovator community.

• Track developments to understand market impacts and regulatory 

implications.

• Identify opportunities to leverage new technology, including AI, at the agency

as well as in markets that the CFTC oversees. 
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Potential Application of AI: 

Market Participant Compliance

Machine 

Accessible 

Rules

Semantic 

Tagging

Participant systems interact with a 

digitized, tagged rulebook. 

Compliance reports and output can 

be automated as well. 

Regulator A

Regulator B

Regulator C

Counterparty A

Counterparty B

AI System

• Transaction lifecycle 

events

• Regulatory reporting

• Margin requirements

• Confirm customer 

account transfers and 

segregation

• Books and records 

capture and archiving

• Trade surveillance

Market 

Participant

AI Systems
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Modern markets are fast-moving, complex networks with numerous participants carrying out 

various functions. Effective oversight supports strong, well-working markets. As a market 

regulator, the CFTC could leverage AI to:

• “Read” a complex marketplace and distinguish salient activity. 

• Use data to develop market models and identify risk factors.

• Apply the models to conduct ongoing market and risk surveillance.

• Help identify market manipulation, abusive trading, and fraud.

AI 

System

Market Data

(Public, Regulatory)

Other Data

CFTC

End Users

Dealers

Clearinghouses

SDRS

Exchanges (SEFs & DCMs)

FCMs

Larger Participants

Potential Application of AI: 

Market Oversight
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Potential Application of AI: 

Potential Spoofing Detection

Price

1005

1004

1003

1002

1001

1000

999

998

997

996

995

Time 09:00:01

An AI system can train on market data and then 

develop a model to detect potentially illicit 

activity. 

AI systems can greatly enhance market 

surveillance with “always on” capability, speed, 

and models that can improve over time.

40 40 45 45 60 60 40 40

50 50 40 40 45 45 35 37

45 45 25 25 100 100 20 32

35 30 15 15 25 30 20 30

25 15 8 8 12 15 15 20

5 10 6 3 4 9 5 10

3 15 20 15 8 3 7 10

15 20 25 18 12 8 15 18

20 100 100 20 19 18 20 20

24 35 38 35 25 24 25 24

32 40 46 33 28 28 30 30

09:00:06

Market Price

Filled Order

Filled Order

Buy Order Buy 

Cancel

Spoofing Order

Sell Order Sell

Cancel

Spoofing Order

Sell

Buy

Large buy order increases 

perceived demand, 

increasing the price. 

Spoofer sells high and 

immediately cancels large 

buy order.

Spoofer then places a large sell 

order to decrease the price and 

buy back the contract.

Result: Sold contracts at 1000, 

bought back contracts at 999
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Predicting catastrophic market events, such as the cascading defaults of 2008, is like predicting the weather. 

There are many variables, which can generate diverging predictions, and some key information may be 

overlooked or not available. This can impede corrective action. 

A strength of AI is its ability to identify correlations in vast data sets. Such correlations can be helpful in 

systemic risk monitoring, which depends on predicting when circumstances may require intervention.

Dodd-Frank Act

Regulatory data includes transaction, 

customer, and account information from 

intermediaries (e.g., exchanges, CCPs). 

Trading platforms and clearinghouses track 

message traffic and participant identities. 

Other Data

Public Mkt 

Data

AI & 

CFTC

Financial Network Data

Laws, Regulations, Guidance

Clearinghouses

Exchanges and 

Intermediaries

News, Events

Potential Application of AI: 

Systemic Risk Monitoring
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Regulatory Implications of AI

• How might AI and related technology impact market structure? How can it enhance the 

quality of our markets?

• New business models.

• New mechanisms for market oversight.

• What safeguards are necessary or appropriate?

• Regarding data acquisition, use, management, distribution, and access.

• Regarding systems resiliency and disaster recovery.

• Regarding undesirable outcomes or performance of AI-based tools.

• Who is accountable and legally responsible for the use of AI in markets the CFTC oversees?

• The CFTC’s current regulatory framework is based around registrants – 

a defined set of market participants.

• Traditionally, third-party service providers provide services to CFTC-registered entities, 

who are legally responsible for compliance. Third-party service providers are not 

separately regulated.

• The proliferation of AI systems with increasing functionality has the potential to blur 

traditional boundaries.
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AI and CFTC Markets

• The CFTC regulates derivatives market activity, not particular technologies.

• Uses of AI may include regulated activities (e.g., customer onboarding, KYC and AML) or 

regulatory requirements (e.g., transaction and position reporting).

• CFTC registrants that use AI, or engage with firms that do, remain responsible for 

compliance with all applicable requirements.

• Where an AI system engages in regulated activity, such work must be conducted on behalf 

of and subject to the direction of a CFTC registrant.

• Use of AI systems by CFTC registrants should comply with all applicable legal rules and 

standards.

• Entities using AI should consider consulting with competent counsel.
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Moving AI Forward • Risks and Challenges • Responding to AI • Key Considerations for AI Development
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Key Challenges and Risks

AI presents opportunity, but also certain risks. Addressing the challenges will facilitate 

AI’s ongoing growth and help enable its value to be fully realized. 

• Operational Risk: To be effective, AI systems must operate as intended. What approaches 

can help ensure that they do?

• Economic Risk: AI systems have economic impact. How can less desirable impacts on 

workers or other aspects of the economy be mitigated?

• Trust: To provide value, AI systems interact with vast amounts of data, including personal 

information. What can be done to maintain public trust? 

• Accountability: AI systems raise novel questions about accountability. If something goes 

awry, who is responsible and for what? Regarding data, what rules apply?

• Security Risk: AI systems are subject to various types of attack and must be resilient. 

What safeguards can mitigate this risk? 
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Responding to AI

While AI has the potential to enhance human capabilities 

and experiences, in their use of AI, financial market 

participants should work to ensure:

• AI systems are working as intended. 

• AI systems are safe and do not generate or exacerbate 

systemic risk. 

• AI systems serve the needs of all relevant stakeholders and 

operate fairly. 

• AI systems protect privacy appropriately and as required.

Further development of AI can benefit from collaboration 

and the open exchange of ideas between market 

participants, regulators, and other stakeholders. Key 

elements of a response include: 

• Development Standards.

• Governance and Oversight.

• Security and Resiliency. 
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AI System Development

AI Systems

• Transparency: Degree to which mechanisms 

providing “explainability” are built into systems.

• Performance: Metrics to assess how the AI 

system performs and quantify output in terms 

of accuracy, false positives, and false negatives. 

• Interoperability: How should systems interface 

with the world and each other?

• Testing Standards: AI systems should be 

rigorously tested before they are implemented 

and as they operate over time.

• Security and Resiliency: Safeguards to protect 

against attacks and manipulation of AI systems, 

and contingency plans to respond.

AI System Data

• Data Sourcing and Integrity: 

Appropriate practices and principles 

for sourcing and safeguarding data, 

including disclosure, rights to review 

and correct, privacy, and anonymity.

• Data Access: Is necessary data 

accessible? How can it be effectively 

used and managed?

• Resiliency: Appropriate practices and 

principles to ensure trustworthiness, 

safety, and resiliency of data storage 

facilities and systems.

A broad spectrum of principles may be useful as AI continues to develop.
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AI System Governance and Oversight

Effective governance and oversight is vital for AI systems. 

Key elements include: 

• Accountability: Who is responsible and for what? 

• Sound Data Policies: Who has the right to capture and use data? To what extent may AI 

systems be deployed on such data? 

• Compliance: What types of licensing or certification may be appropriate?

• Oversight: How will new AI systems be reviewed? How should AI systems be supervised 

as they learn and evolve? How will complaints be addressed?

• AI Development: What principles should guide the design and development of AI 

systems to reflect social standards and support reliable, robust, and trustworthy 

systems?

• AI Economy: How will a diverse, growing set of AI systems interact? How will 

unintended consequences of interactions between multiple AI systems and operators be 

addressed? What common standards may be helpful?
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Security and Resiliency

• AI systems develop and change over time, and 

may not function properly or as intended. There 

could be a design fault or an unanticipated error. 

Data the system uses may be corrupt, biased, or 

incomplete. • What guardrails can prevent AI systems from 

running amok? How can we ascertain when 

AI systems may not be working properly? 

What metrics or approaches may be helpful 

to evaluate AI system operation and 

outcomes? 

• AI systems and data centers can be hacked. AI 

systems can be impacted by adverse data attacks. • What approaches can mitigate these risks? 

What types of deterrence may be most 

effective? How can stakeholders coordinate 

effectively?
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Key Considerations for AI Development

• AI systems depend on good design and ongoing 

monitoring.

• To build effective AI systems, careful 

consideration must be given to the choice of 

algorithms, the sourcing of data, and the 

evolution of AI models.

• Appropriate governance and controls are vital for 

AI to succeed. 

• AI systems assist and augment, but cannot 

replace, human judgment.

• For long-term success, AI systems must be 

reliable, resilient, and trustworthy. 

Implemented responsibly, AI has great potential to enhance our markets.
Questions? 

Contact us at 

LabCFTC@cftc.gov

www.cftc.gov/LabCFTC

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