This Note addresses the novel risks of insider trading for financial firms who implement and use AI systems. There are two primary risks associated with AI use: misalignment and security. Misalignment risk refers to an AI system’s ability to take action beyond its given objectives. Security risk, on the other hand, deals primarily with hacking, data breaches, and internal ethical screening. These risks differ greatly from both human insider trading risk and traditional information technology risk. Humans are subject to social and moral counterweights as well as civil and criminal penalty; AI systems are not. Moreover, traditional IT risk management policies do not account for the development cycle of AI or the presence of emergent properties. As a result, firms should adopt specific policies to address AI created insider trading risk. Policies serve to solidify a firm’s risk management strategy and present easy-to-follow guidance for employees, which will act to prevent insider trading and concurrent liability.