SR 26-2 Footnote 3 — The Enforcement Gap GRACE Closes
SR 26-2 explicitly excludes agentic AI from formal model risk management scope while requiring institutions to self-govern. GRACE intercepts every AI action, documents the SR 26-2 governance scope, and seals a tamper-evident Policy Action Packet — giving examiners the record the regulation requires but does not define.
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BSA/AML SAR Disposition — Every Filing Sealed Before It Executes
AI agents now recommend SAR dispositions — file, escalate, or close. Each is a consequential action with a regulatory obligation attached. GRACE intercepts every SAR recommendation before it reaches the BSA officer, evaluates it against current BSA policy, and seals a complete tamper-evident record the institution owns — not the vendor.
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Fiserv agentOS — One Agreement, 2,700 Banks, Every Action Sealed
Fiserv agentOS brings AI agent capabilities to 2,700 financial institution customers simultaneously. GRACE embeds as the enforcement layer across the entire platform — each institution receives a policy-isolated PAP archive from day one. One OEM agreement delivers examination-ready enforcement to every agentOS deployment at activation.
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AWS AgentCore — The Independent Proof Layer AgentCore Cannot Produce
AWS AgentCore provides policy enforcement for AI agents within AWS infrastructure. It does not produce a cryptographically sealed, institution-owned enforcement record that satisfies independent examination requirements. GRACE runs natively on AWS Lambda and provides the proof layer AgentCore cannot produce for itself. Complementary — not competitive.
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SHADOW Mode — 47-Day Archive, Zero Production Impact
SHADOW mode is how institutions deploy GRACE before they are ready to activate enforcement. GRACE runs in parallel alongside existing operations, builds a complete PAP archive, and produces zero operational impact. No vendor notification. No integration change. The institution enters its next examination cycle with a sealed per-decision governance record from Day 1 of SHADOW activation.
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Federal Air-Gap — FIPS 204, CMMC Level 2, No Cloud Required
GRACE’s software-only architecture enables deployment in air-gapped federal contractor environments with no cloud dependency and no hardware requirement. ML-DSA / FIPS 204 post-quantum cryptographic signing meets federal standards. SAM.gov entity registration is active. SBIR Phase I pathway is open. CMMC Level 2 AI audit trail requirements are satisfied by the PAP architecture.
Interested in a live demonstration?
Every demo is staffed and tailored to your institution's specific context. Fill in your information and we will reach out within 48 hours to schedule your session.
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