- Essays··8 min read
The Certificate You Did Not List
Enterprise procurement teams are embedding ISO 42001 status into vendor questionnaires ahead of the EU AI Act's August 2026 enforcement milestone — and deals are stalling when that field comes back empty. The pattern mirrors how SOC 2 became a contract gate a decade ago, but the timeline is compressed to eighteen months rather than five years. Vendors without an auditable AI management system are not losing on price; they are failing the first screening before negotiation begins.
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Two Ledgers in a Kagome Field
Kagome's AI yield model forecasts harvests five weeks out from soil sensors and satellite pixels; its SSBJ-mandated Scope 3 ledger must account for the same fields in itemised grams of CO2-equivalent. The two models share no instrumentation — a nitrogen prescription that reduces N2O flux does not automatically become a credited emissions delta. That reconciliation is where Japanese food processing will spend the next several years, regardless of whether precision agriculture's sustainability claims hold up.
precision-agricultureclimate-disclosurescope-3-emissionsjapanRead - Essays··10 min read
The Bill That Ended the Pilot
Uber burned its entire annual AI coding budget in four months — the full allocation gone by spring, no controlled overrun flagged in planning. Three-quarters of enterprises watched AI costs blow past budget last year, and the correction now arriving is triage, not enthusiasm. The governance failure and the cost failure are the same failure: if you cannot name who changed the production prompt, what it scored before it shipped, or what spending ceiling it is running under, the debt is already due.
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The Orphan Line Item
The EU AI Act's high-risk AI obligations became enforceable in August 2026 with no harmonised standards published and almost no notified bodies designated — the infrastructure the regulation assumed would exist. What arrives instead is a bill finance did not forecast: third-party conformity assessment at €50,000–150,000 per system, months-long queues for notified-body slots, and recurring annual costs at 20–40% of initial spend. The compliance deadline has moved; the invoice has not.
eu-ai-actregulatory-compliancenotified-bodiesconformity-assessmentRead - Essays··8 min read
The Jakarta Claims Desk After the Copayment Rule
Indonesia's mandatory 10% copayment rule, in force since March 2026, has shifted the distribution of submitted health claims faster than any fraud-detection model calibrated on the old baseline can follow. The real discipline at a Jakarta claims desk is not the AI stack — it is who overrides it, whether those overrides are logged, and whether a coverage-adverse audit exists before the regulator requests one.
health-insuranceai-governanceclaims-processingindonesiaRead - Essays··8 min read
The Agents You Cannot Name
Most enterprises deploying AI agents cannot list what is running, who approved it, or what it costs: a governance gap that is today's operating environment, not a future risk. Agentic workflows trigger ten to twenty LLM calls per task, and token volumes have grown sixty-fold since 2023. The agents you cannot name are the ones that will fail an audit, breach a data policy, or exhaust months of budget because nobody set a spend limit.
ai-governanceagentic-aienterprise-aishadow-aiRead - Essays··8 min read
The PCCP Constraint
The Predetermined Change Control Plan is FDA's mechanism for letting AI-enabled medical devices update without a new submission. It is not a solution to the adaptive-AI problem. It is a scoping exercise written in advance. The modifications a vendor can ship without re-filing are precisely and only those the engineer defined eighteen months before knowing what the field would ask for.
medical-aifda-regulationpccpdigital-pathologyRead - Essays··11 min read
The agentic AI carve-out: why US and EU regulators are writing rules neither can enforce
The Federal Reserve placed agentic AI outside its model-risk framework in April; the European Commission issued transparency guidance two weeks before enforcement began in August. For banks operating across both jurisdictions, the collision is immediate and the governance gap is real. The first regulatory action will likely come for failing to document why deployment was safe at all, rather than for deploying these systems badly.
agentic-aifinancial-regulationmodel-riskeu-ai-actRead - Essays··8 min read
1 million Genomes Later, the Bedside Model Still Waits
The UAE has assembled the most complete sovereign healthcare-AI stack any country has built: sovereign compute, a million-sample national genome programme, and a clinical model benchmarked ahead of GPT-4. The model's own authors say it is not yet fit for clinical use. That caveat is the most precise evidence about where the Gulf investment earns its return: in the biobank and the data-sovereignty infrastructure rather than in the generative layer above them.
genomicsclinical-aiai-governancesovereign-aiRead - Essays··9 min read
The model-risk carve-out: why US banks got a temporary reprieve from agentic AI oversight while EU lenders face their deadline
SR 26-2, the Federal Reserve's updated model-risk guidance, carves generative and agentic AI out of supervisory scope. The carve-out is a placeholder while regulators decide what replaces SR 11-7. The EU AI Act's high-risk obligations arrive on 2 August. For multinational banks, the result is a structural supervision paradox: US headquarters has time but no clarity; European subsidiaries have clarity but no time.
model-riskagentic-aieu-ai-actbanking-regulationRead - Essays··8 min read
The $500 Million Bill Nobody Anticipated: When AI Slop Debt Becomes a Balance-Sheet Problem
An enterprise client burned $500 million on AI services in a single month, a consequence of deferred governance rather than reckless strategy. AI slop debt, the compounding cost of zombie agents, ungoverned prompts, and abandoned POCs that still bill, has crossed from engineering irritation to balance-sheet liability. When 73% of AI initiatives exceed budget, the board question is no longer which use cases to fund but who can turn off what is already running.
enterprise-aiai-governancefinopsai-agentsRead - Essays··8 min read
Harvey Signs at Raffles Place. The Bill Starts Now.
When WongPartnership signed with Harvey, it acquired a seat licence and a compounding stack with it: wrapper-maintenance costs running 30–60% above the sticker, prompt libraries with no clear owner, and a hallucination-liability perimeter across three jurisdictions that Vietnam's new AI statute just made more expensive. The Forrester 400% ROI ceiling belongs to firms with clean, documented processes. Most Southeast Asian mid-market partnerships are not those firms.
legal-aisingaporeai-governanceprofessional-liabilityRead - Essays··8 min read
Riyadh Re, the Cession Ladder, and the Actuarial Weight of a Guidance Note
Saudi Arabia's mandatory cession ladder reached 30% in January 2025; the UAE Central Bank's Guidance Note on responsible AI followed in February. Together they define what the AI story in Gulf insurance actually costs. A domestic reinsurance mandate sits on one side and a documented compliance overhead on the other: annual bias testing, Arabic-language disclosure, mandatory human review at the decision point. The vendor deck prices neither.
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Nadella's Half-Drawn Ledger
Satya Nadella's essay on the reverse information paradox names a real problem: enterprise buyers surrender proprietary knowledge to AI vendors with each query: prompts, corrections, evaluation harnesses. The framing is analytically sound. It is also written by the CEO most commercially exposed to a future in which that knowledge lives outside his cloud tenant. The enterprise buyer's job is to notice which parts of the argument survive when the messenger changes.
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Sunday Essay · Singapore's Rulebook for Agentic Finance
Singapore's Monetary Authority has published the first regulator-authored document to name, at runtime, the exact control gates between an autonomous agent's proposed action and a live ledger. SAFR's policy engine, runtime validator and append-only audit ledger map onto what DBS and Grab Finance already run in production. For model risk officers from Jakarta to Frankfurt, this is the document to read before the vendor decks arrive.
agentic-aifinancial-regulationmodel-riskmas-singaporeRead - Essays··7 min read
Three Clocks Ticking on the Same AI Quarter
Three deadlines are converging on the same AI quarter. One is set by treaty, one by physics, one by the next insurance renewal. Most boards are tracking the first, glancing at the second, and have never heard of the third.
eu-ai-actdata-centre-powerai-liability-insuranceai-governanceRead - Essays··7 min read
The Slop Debt Bill Is Due, and Nobody on the Org Chart Owns It
Slop debt is the space between what you pay for AI and what you do not get. The bill is in the inbox; the question is whether the org chart catches up before the auditor does.
slop-debtfinopsagentic-aiai-governanceRead - Essays··7 min read
200 million to Study the Wave You're Making
A frontier lab has priced in the scenario where its product makes office work unnecessary, and is funding the academics who'll help governments respond. Adoption is wide; realisation is narrow. The gap is now numerical.
enterprise-aiproductivity-paradoxworkforceagentic-deploymentRead - Essays··7 min read
The bill nobody booked
The most expensive line item in your AI budget for the next two years is the one your finance team has not yet named. It is sitting in your environment already, in half-built pilots, ghost fine-tunes and redundant copilots, capitalising itself into your monthly cloud invoice.
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