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Building an AI governance policy your agency can defend

Cipher Defense Research


Public-sector AI governance has a distinctive failure mode: policies written to satisfy a directive, filed in a binder, and never operationalized. When an inspector general or oversight body asks how the policy is enforced, the binder is not an answer.

Defensible means operational

A defensible policy names an owner, defines an approval path employees can actually follow, and specifies what happens when a tool falls outside it. Every clause should map to a mechanism someone can point to under questioning: a review board, a logging requirement, a procurement gate.

Start from what is already in use

Writing policy before inventory produces rules for a hypothetical agency. Discovery first: which AI capabilities are already in use across programs, sanctioned or not, and what data they touch. The policy then governs reality rather than intention.

Keep the paper trail assessor-shaped

Decisions, exceptions, and reviews should generate records as a side effect of the process, not as an after-the-fact reconstruction. If defending the policy requires assembling evidence from memory, the policy is not yet defensible.

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