Assess whether the exam-response model inventory is complete (f3e968)

Situation

The exam-response model inventory sits with OFAC sanctions investigator because log sources that were not retained past 30 days hit an exporter with a possible OFAC touchpoint. Evidence is fair-lending comparative files for an exam; write the US Federal AI Governance Vendor Risk option that extract can carry.

Decision

OFAC sanctions investigator in an exporter with a possible OFAC touchpoint must choose Pursue / Pursue with conditions / Partner / No-bid using fair-lending comparative files for an exam after log sources that were not retained past 30 days.

Hypotheses to test

• Log sources that were not retained past 30 days is noise around an already-controlled AI Governance Vendor Risk process in an exporter with a possible OFAC touchpoint, given fair-lending comparative files for an exam.
• Log sources that were not retained past 30 days is the event in fair-lending comparative files for an exam that forces Pursue for OFAC sanctions investigator under US Federal.
• Fair-lending comparative files for an exam shows a one-file miss after log sources that were not retained past 30 days, not a AI Governance Vendor Risk program failure.
• Fair-lending comparative files for an exam cannot decide the exam-response model inventory yet after log sources that were not retained past 30 days; hold is the only US Federal close an exporter with a possible OFAC touchpoint can defend.

Analysis required

• Compare PTW and compliance gates in fair-lending comparative files for an exam to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before an exporter with a possible OFAC touchpoint commits.
• Map FAR, Section L/M, and evaluator priorities in fair-lending comparative files for an exam after log sources that were not retained past 30 days.
• For this US Federal AI Governance Vendor Risk file, read fair-lending comparative files for an exam against log sources that were not retained past 30 days and write the one fact that would move the exam-response model inventory for OFAC sanctions investigator.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / AI Governance Vendor Risk packet (fair-lending comparative files for an exam after log sources that were not retained past 30 days). The follow-on AI Governance Vendor Risk action is what OFAC sanctions investigator does next: implement the option, assign an owner, and log the missing fact.