Goldman Sachs Revises Business Conduct Code to Tighten AI, Market Rules

Goldman Sachs has revised its Code of Business Conduct and Ethics to tighten controls around artificial intelligence, internal communications and market conduct, changes that will reshape day-to-day compliance for deal teams, technologists and front-office staff. The firm consolidated expectations for employee behavior, clarified reporting channels and linked new guidance on AI use with existing market-conduct policies.

The corporate code stresses regulatory foundations and entity-level adoption. Goldman Sachs BDC, Inc.’s code cites Sarbanes-Oxley and NYSE rules, noting that the SEC “has adopted rules requiring annual disclosure of an investment company’s code of ethics” and that the NYSE “requires that a listed company adopt and disclose a code of business conduct and ethics for directors, officers and employees.” Parallel documents for GS Acquisition Holdings Corp II reflect similar language and board-level oversight, including an explicit duty to “notify Compliance promptly” of any potential or actual breach.

The updated firmwide language reaffirms that Goldman Sachs is “committed to ensuring compliance with relevant market conduct laws and has implemented policies and procedures to mitigate the following market conduct risks: conduct and supervision, confidentiality and communication, market manipulation, collusion, conflicts of interest, and inappropriate sales practices.” That list frames practical obligations: business communications must run on firm-approved systems, and personal messaging platforms such as WhatsApp or WeChat are “not authorized” for business communications beyond logistical discussions. All employees and contingent workers remain required to affirm they have reviewed the Code and will comply with it.

The revisions also intensify expectations around escalation and accountability. Employees are reminded to escalate market-conduct concerns “per the firm’s issue escalation policy guidelines,” and entity codes underscore that failure to report may itself be a breach. Discipline carries real consequences: “The firm will take any disciplinary or preventative action deemed necessary and appropriate to address existing or potential violations of this Code, up to and including termination of employment,” and violations “may also constitute violations of law, which may result in criminal or civil penalties for individual employees and/or the firm.”

Vendors and third parties are swept into the compliance net through the Goldman Sachs Vendor Code of Conduct, posted as “Published January 2022,” which requires suppliers to align policies across their supply chains, be “open and cooperative with the regulators,” and report any facts likely to prevent them from meeting the Code’s standards to their Goldman Sachs relationship manager.

For employees this means more formal controls over how models, data and communications are used, a likely increase in attestations and training, and closer supervision by managers and compliance. Teams that rely on nonfirm messaging or experimental AI tools should expect faster escalation paths and stricter documentation requirements. With board oversight emphasized and entity-level codes tied to SEC and NYSE standards, the revisions signal that Goldman Sachs is treating AI governance and communication controls as integral to market-conduct risk management.

What comes next for workers is greater operational clarity but also heightened enforcement: expect rollouts of detailed guidance, training on approved systems and AI use, and routine attestations as the firm translates code language into day-to-day policy and supervision.