Assess whether an OFAC match is true and requires blocking (fc2558)

Situation

AI procurement evaluation that skipped bias testing arrived with log sources that were not retained past 30 days for IG improper-payments investigator. That is a US Federal AI Governance Vendor Risk decision on an OFAC match is in an IG shop scoping a whistleblower allegation.

Decision

IG improper-payments investigator in an IG shop scoping a whistleblower allegation must choose Pursue / Pursue with conditions / Partner / No-bid using AI procurement evaluation that skipped bias testing 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 IG shop scoping a whistleblower allegation, given AI procurement evaluation that skipped bias testing.
• Log sources that were not retained past 30 days is the event in AI procurement evaluation that skipped bias testing that forces Pursue for IG improper-payments investigator under US Federal.
• AI procurement evaluation that skipped bias testing shows a one-file miss after log sources that were not retained past 30 days, not a AI Governance Vendor Risk program failure.
• AI procurement evaluation that skipped bias testing cannot decide an OFAC match is yet after log sources that were not retained past 30 days; hold is the only US Federal close an IG shop scoping a whistleblower allegation can defend.

Analysis required

• Test OCI and SAM.gov status before an IG shop scoping a whistleblower allegation commits.
• Map FAR, Section L/M, and evaluator priorities in AI procurement evaluation that skipped bias testing after log sources that were not retained past 30 days.
• Name the evaluation right IG improper-payments investigator would forfeit by rushing.
• For this US Federal AI Governance Vendor Risk file, read AI procurement evaluation that skipped bias testing against log sources that were not retained past 30 days and write the one fact that would move an OFAC match is for IG improper-payments investigator.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / AI Governance Vendor Risk packet (AI procurement evaluation that skipped bias testing after log sources that were not retained past 30 days). If AI procurement evaluation that skipped bias testing cannot force a US Federal label under AI Governance Vendor Risk, stop. If AI procurement evaluation that skipped bias testing after log sources that were not retained past 30 days cannot support Pursue versus Pursue with conditions on this US Federal AI Governance Vendor Risk close, IG improper-payments investigator must identify the Section L/M or evaluation criterion that remains unproven rather than filling the gap.