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Case Detail

RS-AI-2024-0001

DemoAI Governance Ltd. · ai — an illustrative sample of the obligation-to-decision journey, on fixed example data.

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Risk Level
critical
Risk Score
88
Status
under review
Customer Profile
corporate / high
Route
EU → EU
Company & Applicability

DemoAI Governance Ltd.

Applicability Rationale · APP-AI-01

DemoAI Governance Ltd. operates ai governance review in scope of the frameworks above.

In-scope Frameworks
EU AI ActDORAAMLA 2027
Obligation Intelligence

Triggered Obligations

Regulation → Obligation → Control → Evidence → Decision

OBL-AI-01criticalEU AI Act
High-Risk AI System — Conformity Assessment Missing

AI Act Article 43 requires conformity assessment before deployment of Annex III systems. System currently in production without certification.

Documented evidence demonstrating compliance with High-Risk AI System — Conformity Assessment Missing (EU AI Act).

OBL-AI-02highEU AI Act
FRIA Not Completed

Fundamental Rights Impact Assessment required under AI Act Article 27 for credit decisioning. Assessment absent.

Documented evidence demonstrating compliance with FRIA Not Completed (EU AI Act).

OBL-AI-03highEU AI Act
Human Oversight Controls Inadequate

AI Act Article 14 requires documented human override capability. Current system lacks override audit trail.

Documented evidence demonstrating compliance with Human Oversight Controls Inadequate (EU AI Act).

OBL-AI-04mediumDORA
DORA ICT Risk — AI Vendor Contract Gap

AI model vendor contract missing DORA-required ICT concentration risk and exit strategy clauses.

Documented evidence demonstrating compliance with DORA ICT Risk — AI Vendor Contract Gap (DORA).

Risk · RSK-AI-01

Risk Posture

critical
88inherent risk score
Risk Drivers
  • Inherent critical risk from ai governance review
Decision · DEC-AI-01

Escalate — immediate compliance action required

highpending human review
Rationale

AI Act High-Risk System — Credit Decisioning Model Without FRIA. 4 regulatory obligation(s) triggered; residual critical risk requires the action(s) below.

Regulatory Basis
EU AI ActDORA
Decision Explainability · 8-Question Contract

Why This Decision?

Decision DEC-AI-01 · Escalate — immediate compliance action required

highpending human review
1
Why this decision?
AI Act High-Risk System — Credit Decisioning Model Without FRIA. 4 regulatory obligation(s) triggered; residual critical risk requires the action(s) below.
2
Why not the alternative?
  • Elevated — enhanced due diligence required — Not taken because the required condition was not met: high inherent risk.
  • Review — scheduled compliance review — Not taken because the required condition was not met: medium inherent risk.
  • Monitor — no immediate action — Not taken because the required condition was not met: low inherent risk.
3
Which regulation applies?
EU AI ActDORA
4
Which obligations apply?
  • OBL-AI-01High-Risk AI System — Conformity Assessment MissingAI-ACT
  • OBL-AI-02FRIA Not CompletedAI-ACT
  • OBL-AI-03Human Oversight Controls InadequateAI-ACT
  • OBL-AI-04DORA ICT Risk — AI Vendor Contract GapDORA
5
Which evidence supports it?
  • EVD-AI-01OBL-AI-01pending
  • EVD-AI-02OBL-AI-02pending
  • EVD-AI-03OBL-AI-03pending
  • EVD-AI-04OBL-AI-04collected
6
What assumptions were used?
  • 'risk_level' was taken at face value from the supplied data.data
  • 'suspicious_pattern_flag' was taken at face value from the supplied data.data
  • 'source_of_funds_status' was taken at face value from the supplied data.data
  • 'cross_border' was taken at face value from the supplied data.data
  • 'kyc_status' was taken at face value from the supplied data.data
7
What is the confidence?
highderived from the risk drivers below
  • Inherent critical risk from ai governance review
8
What should happen next?
ACT-AI-01Commission AI Act conformity assessment (Annex III)
Human Review

Human-review status: pending human review. Deterministic sample scenario for demonstration — not legal advice; a material decision requires an authorised compliance officer.

Deterministic sample — decision support, not autonomous enforcement. Not legal advice.

Case Summary

Operational decision context

Transaction
N/A 0
Transaction Count (24h)
0
KYC Status
not applicable
Sanctions Screening
not applicable
Source of Funds
not applicable
Flags
PEP: No / Suspicious: No / Cross-border: No
Notes

High-risk AI system deployed in credit decisioning without FRIA or conformity assessment

Narrative

AI system deployed in credit decisioning classified as high-risk under EU AI Act Annex III. No Fundamental Rights Impact Assessment (FRIA) on file. Human oversight controls are insufficiently documented. Conformity assessment required before continued deployment.

Actions

Recommended next steps

ACT-AI-01OBL-AI-01
Commission AI Act conformity assessment (Annex III)
AI Governance · pending
immediate
ACT-AI-02OBL-AI-02
Complete Fundamental Rights Impact Assessment (FRIA)
Legal & Compliance · pending
high
ACT-AI-03OBL-AI-03
Implement human oversight audit trail for model decisions
Engineering · pending
high
ACT-AI-04OBL-AI-04
Update AI vendor contract with DORA ICT clauses
Legal · pending
medium
Controls

Operating controls

View controls →
Control: High-Risk AI System — Conformity Assessment Missing
CTL-AI-01OBL-AI-01Continuous / Per Case
gap
Control: FRIA Not Completed
CTL-AI-02OBL-AI-02Per Case
gap
Control: Human Oversight Controls Inadequate
CTL-AI-03OBL-AI-03Per Case
gap
Control: DORA ICT Risk — AI Vendor Contract Gap
CTL-AI-04OBL-AI-04Quarterly
operating
Report · RPT-AI-01

Audit-ready report

View report →
Decision
DEC-AI-01
Risk
critical · 88
Obligations
4
Evidence Collected
1 / 4
Actions
4
Regulatory Basis
EU AI Act, DORA