Exploring Legal Conflict of Interest

  • Release version: Zurich
  • Updated March 12, 2026
  • 4 minutes to read
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    Summary of Exploring Legal Conflict of Interest

    The ServiceNow® Legal Conflict of Interest (COI) application helps organizations manage the disclosure, approval, and registry of potential conflicts of interest arising from employees' competing interests or loyalties. Employees can submit COI disclosures either through the Employee Center intake form or via the conversational interface of ServiceNow Otto in Virtual Agent (the latter requires the paid Legal Service Delivery - Prime application).

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    Each submission undergoes an automated risk assessment based on predefined risk factors, resulting in a risk score that determines the approval workflow routing. This automation streamlines COI management by prioritizing requests and accelerating approvals.

    Risk Assessment

    The risk assessment evaluates submissions using three types of criteria:

    • Condition: Rule-based field-value evaluations for deterministic checks.
    • Skill: AI-driven analysis of disclosure content to generate risk scores (requires Legal Service Delivery - Prime).
    • Subflow: Custom Flow Designer subflows for complex logic or integrations.

    Based on the overall risk score, requests are classified as Low, Medium, or High risk:

    • Low risk: Auto-approved without engaging approvers; notifications sent to employee and manager.
    • Medium risk: Routed to first-level approvers (e.g., manager and legal compliance).
    • High risk: Routed through a full approval chain including escalated approvers (e.g., board approval).

    Legal fulfillers receive detailed risk assessment reports, enabling faster, informed decisions. Requesters are notified prior to COI record expiry and can resubmit requests for extensions.

    Approval Workflow

    Approval workflows are configurable based on conflict type and risk level. For example, Outside Employment disclosures typically require two approval levels: first the manager, then the legal compliance group. Administrators can customize the number of approval levels and approvers for each conflict type to align with organizational policies.

    Roles

    • Legal Conflict of Interest Admin: Configures intake forms and approval workflows.
    • Legal Conflict of Interest Fulfiller: Reviews and processes COI requests.
    • Legal Conflict of Interest Read-only: Views COI disclosure records without editing rights.

    Workflow Summary

    • The employee submits a COI disclosure selecting the appropriate conflict type.
    • The system performs risk assessment and assigns a risk level.
    • The request enters the corresponding approval workflow.
    • Legal fulfillers review risk reports and approve or reject the request.
    • The final decision is communicated to the employee via email and recorded in the system.

    Benefits

    • Natural language COI submission: Enables easy submission through ServiceNow Otto conversational interface (requires Legal Service Delivery - Prime).
    • Employee Center intake: Alternative submission via a standard form.
    • Automated risk assessment: Configurable risk factors automate approval routing to improve efficiency.
    • Detailed risk reports: Provide transparency and support quicker decision-making by legal fulfillers.
    • Configurable approval flows: Align workflows with organizational COI policies and compliance requirements.

    Next Steps

    ServiceNow customers can explore configuration and usage details to tailor the Legal Conflict of Interest application to their organizational needs, ensuring efficient and compliant COI management.

    Learn more about the Legal Conflict of Interest application through a sample workflow and review the benefits that it can provide.

    Legal Conflict of Interest overview

    The ServiceNow® Legal Conflict of Interest enables you to manage the disclosure, approval, and registry of conflict of interest that might arise from employees having competing interests or loyalties. Employees can submit disclosures using the conversational interface of ServiceNow Otto in Virtual Agent or intake form available in the Employee Center. The Requests are evaluated against predefined risk factors to calculate an overall risk score. Based on this score, requests are routed to the appropriate approval workflow for faster resolution.

    Note:
    The conversational intake functionality is available only when you have installed and configured Legal Service Delivery - Prime that is a paid application. For more information, see ServiceNow Otto for Legal Service Delivery (LSD).
    For more information on how to submit the requests using the two methods, see Submit COI request form Employee Center and Submit COI request using ServiceNow Otto conversational intake

    Risk assessment

    When an employee submits a COI disclosure—either through the Employee Center intake form or via ServiceNow Otto in Virtual Agent conversational intake—the risk assessment utility evaluates the submission against a set of predefined risk factors. Each risk factor contributes to an overall risk score, which determines the risk level (Low, Medium, or High) and the corresponding approval routing.

    The risk level determines whether the request needs approval or can be auto-approved.
    • Low risk — The request is auto-approved, and both the employee and their manager receive notification. No approvers are engaged.
    • Medium risk — The approval chain is triggered. The request is routed to the first-level approvers as determined by the conflict type (for example, Manager and Legal Compliance for an Outside Employment disclosure).
    • High risk — The full approval chain is triggered, including escalated approvers. The request is routed through all approvers defined for the conflict type (for example, Manager, Legal Compliance, and Board Approval for a Board Service fiduciary role).

    Risk factors support three evaluation types that determine how each condition is assessed:

    • Condition: Evaluates the disclosure against rule-based field-value conditions. Use this type for deterministic, field-based evaluations.
    • Skill: Uses an AI skill to analyze the disclosure content and return a risk score. This evaluation type is available only when you have installed and configured Legal Service Delivery - Prime plugin (sn_lg_ai_prime), which is a paid application.
    • Subflow: Executes a Flow Designer subflow for complex logic, external integrations, or multi-step processing.

    The risk assessment process generates a report that provides legal fulfillers visibility into the evaluation. The report includes request details, risk level and score, detailed risk factor analysis with reasoning, and all submitted request variables. Legal fulfillers can review the report from the Risk Assessment tab of the legal request to take quicker decisions.

    A notification is sent to the requesters before the expiry of the validity of their COI disclosure records. If the requesters need an extension, they should review and resubmit a request to get the legal clearance for the extended period.

    For more information, see Configure risk assessment.

    Approval workflow

    The approvers and the number of approval levels differ based on the conflict type.

    Following illustration shows the approvers and number of approval levels for each conflict type. For example, the Outside Employment conflict type has two approval levels. The first-level approver is the manager of the requester, and the second-level approver is the legal compliance group.
    Figure 1. Conflict of Interest approval flow
    Conflict of Interest approval flow for different conflict types.
    The administrator can modify the approval flow in the following ways:
    • Change the number of levels of approval required.
    • Add or modify approvers or approver groups at each level of approval.

    For more information, see Configure flows for Legal Conflict of Interest.

    Legal Conflict of Interest users

    Table 1. Users
    User Description
    Legal conflict of interest Admin Configures intake forms and approval workflows.
    Legal conflict of interest fulfiller Works on fulfilling the COI requests.
    Legal conflict of interest read Has read-only access to view all COI disclosure records.

    Legal Conflict of Interest workflow

    1. The legal user submits a new conflict of interest disclosure request by selecting the appropriate conflict type.
    2. The risk assessment evaluates the request and assigns a risk level (Low, Medium, or High) based on the calculated risk score.
    3. The conflict of interest disclosure request enters a predefined approval workflow depending on the risk level.
    4. The conflict of interest fulfiller reviews the risk assessment report.
    5. The conflict of interest fulfiller either approves or rejects the submitted request.
    6. The final decision is communicated to the employee via email notification.
    7. A corresponding record is automatically generated in the system.

    Legal Conflict of Interest benefits

    Table 2. Legal Conflict of Interest benefits
    Benefit Feature Users
    Submit COI request using natural language from the conversational interface of ServiceNow Otto in Virtual Agent.

    This is available only when you have installed and configured Legal Service Delivery - Prime that is a paid application.

    Submit COI request using ServiceNow Otto conversational intake Legal user
    Submit COI request from the Employee Center Submit COI request form Employee Center Legal user
    Risk assessment with configurable risk factors and score to automate approval workflow Configure risk assessment Legal fulfiller
    Risk assessment reports with detailed scoring and analysis enable legal fulfillers to make faster, informed approval decisions. View risk assessment details Legal fulfiller
    Configurable approval flows in accordance with the organization's Conflict of Interest (COI) policy. Configure flows for Legal Conflict of Interest Legal administrator