Control owners and evidence repositories
Program Timeline: Weeks 3-12
Map RMF/SSDF; define gates; draft SOPs
RBAC, logging, evaluations, HTI-1 (if applicable)
Control tests, tabletop exercises, remediation
Evidence index, narratives, 90-day plan
Weeks 3-5: Control design and crosswalk
Finalize RMF ↔ AI 600‑1 ↔ SSDF (SP 800‑218/218A) mappings per SDLC stage; define pass/fail gates.
Draft SOPs: data intake and provenance, model change control, evaluation/red‑team, runtime logging, override/kill‑switch drills.
FTC pre‑clearance: implement claims inventory, substantiation templates, and approval workflows consistent with the FTC substantiation standard and enforcement posture from Operation AI Comply.
SEC incident readiness: build materiality playbooks, escalation ladders, counsel/board brief templates, and 1.05 timeline trackers per the SEC cybersecurity disclosure rule.
Outcome: Clear release gates and pre-cleared claims reduce regulatory exposure and create defensible audit trails across the SDLC.
Weeks 6-9: Implementation and instrumentation
Enforce RBAC for agent tools and data; implement allow‑lists and policy checks.
Deploy runtime logging schemas for prompts, tool calls, decisions, and overrides; enable secure, tamper‑evident storage.
Publish evaluation and red‑team plans; run genAI‑specific abuse tests aligned with SP 800‑218A practices; implement regression gates.
If healthcare is in scope: assemble HTI‑1 DSI transparency artifacts and user‑facing disclosures per the final rule.
Train GTM, product, and incident‑response teams on SOPs and evidence capture.
Outcome: Instrumentation and gated evaluations shorten incident MTTR, support SEC reporting, and enable repeatable safe releases.
Weeks 10-11: Testing and drills
Control testing: sample transactions/logs, re‑perform evaluations, verify approvals and segregation of duties.
Tabletops: FTC claim challenge, SEC materiality scenario, and HTI‑1 transparency review; capture decisions and improvements.
Remediate gaps; update the Control Inventory & Residual‑Risk Ledger.
Outcome: Evidence-backed control assurance and scenario playbooks form the backbone of audit defense and board oversight.
Week 12: Audit pack and board briefing
Compile evidence index with hashes; prepare control narratives and test results.
Deliver risk posture, residual‑risk ledger, 90‑day remediation plan, and board briefing materials.
Outcome: An audit pack with immutable evidence accelerates diligence, reduces audit friction, and enables credible external disclosures.
Deliverables and evidence index
18-24 month outlook: what auditors and regulators will expect
Wider adoption of NIST‑anchored AI management controls as enterprises harmonize risk and secure‑development practices around the AI RMF and SSDF (see AI RMF 1.0).
Continuation of FTC scrutiny of AI representations and implied claims in marketing and product UX, with more cases testing the boundaries of substantiation standards in digital products.
Normalized SEC reporting workflows for AI‑linked cyber incidents, tighter timeliness controls, and board‑level oversight reporting per the SEC cybersecurity disclosure rule.
In healthcare, maturing HTI‑1 DSI transparency implementations with stronger provenance, validation, and end‑user disclosures as organizations align to the final rule and FAVES expectations (FAVES).
Operationalized incident response for agentic failures with measurable MTTR improvements where teams integrate AI‑specific detection, override drills, and post‑incident learning loops guided by SP 800‑61r3 and RMF measurement practices.
Appendix: control checklists and sampling tips
Design-time controls (sample)
Data provenance verified; consent and license terms recorded; sensitive attributes cataloged.
Threat models include prompt injection, tool‑use abuse, model extraction, and privacy leakage.
Evaluation plans specify reliability, safety, robustness, and misuse tests; acceptance criteria defined in advance.
Run-time controls (sample)
RBAC enforced on agent tools; policy‑checked tool calls with bounded parameters.
Structured logs for prompts, tools, decisions, overrides; retention and access controls applied.
Kill‑switch tested quarterly; results logged and reviewed by Security and Product.
Audit sampling
Sample 15-25 high‑risk agent runs; verify end‑to‑end traceability from prompt → tool calls → outputs → human approvals → outcomes; reject any sample missing a named owner or immutable artifact hash.
Re‑perform two evaluation suites per released model version; match results to published claims.
Review three incident determinations for timeliness and completeness against SEC 1.05 criteria.