Federal AI Governance

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CGS helps government agencies, universities, healthcare systems, financial institutions, and contractors close the compliance gap — before an audit, lawsuit, or breach forces the issue.

Enterprise Compliance · Operational Oversight · AI Governance

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AI-generated records now subject to FOIA disclosure
EO 14110 compliance deadlines are active
NIST AI RMF adoption is no longer optional for federal contractors
SR 11-7 AI model risk requirements expanding
HIPAA guidance now covers AI clinical decision tools
False Claims Act exposure for AI procurement violations
AI-generated records now subject to FOIA disclosure
EO 14110 compliance deadlines are active
NIST AI RMF adoption is no longer optional for federal contractors
SR 11-7 AI model risk requirements expanding
HIPAA guidance now covers AI clinical decision tools
False Claims Act exposure for AI procurement violations
AI-generated records now subject to FOIA disclosure
EO 14110 compliance deadlines are active
NIST AI RMF adoption is no longer optional for federal contractors
SR 11-7 AI model risk requirements expanding
HIPAA guidance now covers AI clinical decision tools
False Claims Act exposure for AI procurement violations
0+

Years Federal Experience

0

Sectors Served

0

Governance Layers

0

AI Governance Niches

The Risk Is Real

EVERY SECTOR FACES
MOUNTING REGULATORY
EXPOSURE.

The question is no longer whether your organization will face AI governance scrutiny — it is whether you will be prepared when it arrives. The regulatory landscape has shifted dramatically, and the consequences of non-compliance are severe.

🏛

Government Agencies

FOIA non-compliance for AI-generated records. Consequence: Litigation, IG investigations, congressional scrutiny.

5 U.S.C. § 552EO 14110OMB M-24-10
Get an Assessment →
📋

Prime Contractors

AI procurement violations & vendor governance gaps. Consequence: Contract termination, debarment, False Claims Act exposure.

FAR/DFARSCMMCNIST AI RMF
Get an Assessment →

Healthcare Systems

AI clinical decision tools without governance frameworks. Consequence: HIPAA violations, FDA scrutiny, malpractice liability.

HIPAAFDA AI/ML GuidanceONC Rules
Get an Assessment →
🏦

Financial Institutions

AI model risk without SR 11-7 alignment. Consequence: Regulatory sanctions, enforcement actions, reputational damage.

SR 11-7OCCCFPB AI Guidance
Get an Assessment →
🎓

Universities

AI in research without IRB/data governance protocols. Consequence: Federal grant suspension, accreditation risk, FERPA exposure.

FERPANSF/NIH AI PolicyIRB Requirements
Get an Assessment →

Regulated Industries

Unstructured AI deployment without oversight frameworks. Consequence: Sector-specific enforcement, class action exposure.

Sector AI RegsGap AssessmentRapid Deployment
Get an Assessment →
Assess Your Risk

Founder & Principal

Vernon Curry

0+ years federal governance leadership
Records management · Privacy law · FOIA compliance

About CGS

EXPERTISE
THAT MATTERS.

Curry Governance Solutions (CGS) helps organizations govern artificial intelligence responsibly. We work with government agencies, contractors, healthcare systems, financial institutions, and universities to build the governance structures, policies, and risk oversight needed to deploy AI safely, transparently, and in compliance with regulatory requirements.

CGS brings more than 15 years of federal governance leadership and regulatory compliance expertise, drawing on deep experience in records management, privacy law, FOIA compliance, and enterprise governance — the exact disciplines that now sit at the center of AI regulatory scrutiny.

15+ Years Federal ExperienceFOIA & Privacy SpecialistsNIST AI RMF AlignedAudit-Ready Frameworks

Sectors We Serve

Federal & State Government Agencies

CGS helps government agencies implement AI governance frameworks that comply with Executive Order 14110, NIST AI RMF, OMB M-24-10, and agency-specific requirements. We provide the governance structures needed to deploy AI systems responsibly within federal environments — including FOIA compliance for AI-generated records, a rapidly emerging area of regulatory exposure.

EO 14110NIST AI RMFOMB M-24-10FOIA Compliance

The Challenge

YOUR REGULATORY
EXPOSURE IS GROWING.
YOUR GOVERNANCE ISN'T.

Organizations implementing AI must balance innovation with responsible governance. Without the right structures in place, the risks regulatory, operational, and reputational compound fast.

CGS helps organizations close the compliance gap before an audit, lawsuit, or breach forces the issue.

“In highly regulated industries, solutions don't fail because of technology — they fail because of poor governance.”

— Curry Governance Solutions

What We Do

THREE CORE
SERVICE LANES

CGS organizes its work into three distinct practice areas, each addressing a different dimension of governance risk. Organizations may engage one lane or all three, depending on their current exposure and maturity.

EO 14110NIST AI RMFHIPAAOMB M-24-10CMMCSR 11-7DoD AI EthicsFAR ComplianceFDA AI/MLCFPB AI FairnessJAIC PrinciplesISO 42001EU AI ActModel Risk Mgmt

01The Foundation

Enterprise Compliance

Traditional compliance work that every regulated organization needs — records management, FOIA compliance, privacy frameworks, and regulatory alignment. CGS brings 15+ years of federal expertise to build the compliance infrastructure your organization requires.

  • Records Management & Retention
  • FOIA Compliance Programs
  • Privacy Act Implementation
  • Regulatory Gap Analysis
  • Policy Development & Review
  • Compliance Training Programs

Government Agencies · Universities · Healthcare · Finance

02Governance Systems

Operational Oversight

Enterprise governance systems that ensure your organization has the structures, processes, and accountability mechanisms to manage risk at scale. From oversight bodies to audit frameworks, CGS builds the governance infrastructure that regulators and auditors expect to see.

  • Governance Framework Design
  • Oversight Body Establishment
  • Audit Readiness Programs
  • Risk Management Systems
  • Internal Control Frameworks
  • Executive Accountability Structures

All Sectors · Enterprise Organizations · Regulated Industries

03Expertise — Three Focus Areas

AI Governance

Narrow, premium AI governance work in three high-demand areas where CGS has deep expertise and where regulatory pressure is most acute. Not generalist AI consulting — specific, defensible governance for the areas that matter most.

  • FOIA & AI Records Compliance
  • AI Procurement & Vendor Governance
  • AI Risk for Regulated Industries
  • NIST AI RMF Implementation
  • AI Policy Development
  • Algorithmic Transparency Frameworks

Federal Agencies · Contractors · Healthcare · Finance · Universities

Not sure which service fits your situation?

Tell us your governance challenge and we'll map it to the right solution.

Get a Free Governance Assessment

AI Governance Niche

THREE AREAS WHERE
CGS SPECIALIZES.

Rather than claiming expertise in all things AI, CGS has narrowed its AI governance practice to three high-demand, high-consequence areas where our federal background creates a genuine competitive advantage.

01Highest Demand

FOIA & AI Records Compliance

02High Demand

AI Procurement & Vendor Governance

03Growing Demand

AI Risk for Regulated Industries

01 — Highest Demand

FOIA & AI Records Compliance

The single most underserved and rapidly growing area of AI governance. As agencies deploy AI systems, every decision, recommendation, and output becomes a potential federal record subject to FOIA disclosure. Most organizations have no framework for this.

Why This Matters Now

AI-generated records are now subject to FOIA requests. Agencies that cannot identify, retrieve, and appropriately withhold AI records face litigation, IG investigations, and congressional scrutiny. The DOJ and NARA have issued guidance — but few agencies have implemented it.

5 U.S.C. § 552 · NARA Guidance · DOJ FOIA Policy

Key Deliverables

  • AI Records Inventory & Classification
  • FOIA Response Protocols for AI Records
  • Retention Schedule Development
  • Exemption Analysis Frameworks
  • Staff Training & SOPs
Discuss This Service

Proprietary Framework

Phase 1

Assessment

Fixed-Fee · 2–4 Weeks

Phase 2

Implementation

Project-Based · 30/60/90 Days

Phase 3

Ongoing Monitoring

Retainer · Monthly

Phase 1 · Fixed-Fee · 2–4 Weeks

Assessment

A structured, fixed-fee assessment that identifies your current governance posture, regulatory exposure, and priority gaps. Delivered as a written report with a risk score and actionable recommendations.

Deliverables

AI Readiness Audit ReportCompliance Gap AnalysisRisk Exposure Score (5-dimension)Priority Remediation RoadmapRegulatory Alignment Review

THE CGS 7-LAYER
RESPONSIBLE AI
GOVERNANCE MODEL™

The CGS 7-Layer Responsible AI Governance Model™ is structured as a three-phase engagement — concentrated on the governance areas that matter most: Assessment, Implementation, and Ongoing Monitoring.

Each phase maps to specific governance layers and produces concrete deliverables — designed for organizations where deploying AI without a structured governance layer is not an option.

07Continuous Monitoring
06Oversight & Accountability
05Compliance & Regulatory Align.
04Transparency & Explainability
03Risk Assessment & Management
02Data Governance & Privacy
01AI Governance Policy

CGS Responsible AI Governance Framework™

Layer Breakdown

01

AI Governance Policy

Establishing foundational policies that define responsible AI use, accountability structures, and organizational commitments to ethical deployment.

02

Data Governance & Privacy

Implementing robust data management frameworks that ensure privacy compliance, data quality, and responsible data stewardship across AI systems.

03

Risk Assessment & Management

Identifying, evaluating, and mitigating AI-related risks across regulatory, operational, reputational, and ethical dimensions.

04

Transparency & Explainability

AI decision-making made auditable and understandable to all stakeholders, regulators, and the public.

05

Compliance & Regulatory Alignment

Mapping AI systems to applicable federal and sector-specific regulations — NIST AI RMF, EO 14110, HIPAA, SR 11-7, and more.

06

Oversight & Accountability

Defined roles, responsibilities, oversight bodies, and escalation paths for AI governance across the enterprise.

07

Continuous Monitoring

Sustained regulatory compliance, performance tracking, and public confidence through ongoing AI risk monitoring and audit readiness.

Easy Entry Points

START WHERE YOU ARE.

Not every engagement needs to start with a full framework deployment. CGS offers structured, fixed-fee entry points that deliver immediate value and create a clear path to deeper engagement.

Most Popular

AI Readiness Audit

Fixed-Fee · 2-Week Turnaround

A comprehensive assessment of your organization's current AI governance posture. Identifies gaps, quantifies risk exposure, and delivers a written report with a prioritized remediation roadmap.

  • AI Systems Inventory Review
  • Regulatory Gap Analysis
  • 5-Dimension Risk Score
  • Written Assessment Report
  • 30-Minute Debrief Call
Request Audit

Compliance Gap Assessment

Fixed-Fee · 1-Week Turnaround

A focused assessment that identifies your top five compliance risk areas and provides specific, actionable guidance for each. Ideal for organizations that need to understand their exposure quickly.

  • Top 5 Risk Area Identification
  • Regulatory Requirement Mapping
  • Priority Action List
  • Executive Summary Report
  • Follow-Up Q&A Session
Request Assessment

30/60/90-Day Compliance Build

Project-Based · Structured Rapid Deployment

A structured engagement that deploys a governance framework, policy suite, and oversight structure in 30, 60, or 90 days — depending on scope. Built for organizations that need to move fast.

  • Governance Framework Design
  • Policy Suite Development
  • Oversight Structure Setup
  • Staff Training & SOPs
  • Implementation Verification
Get Started

Specialized Service

FOIA AI Records Review

Fixed-Fee · Specialized Service

A specialized assessment for agencies and organizations with AI systems that may generate records subject to FOIA disclosure. Includes retention schedule review and response protocol development.

  • AI Records Inventory
  • FOIA Applicability Analysis
  • Retention Schedule Review
  • Response Protocol Development
  • Staff Guidance Document
Request Review

Enterprise SaaS Platform

CGS AI GOVERNANCE &
RECORDS INTELLIGENCE
PORTAL™

An enterprise-grade SaaS platform purpose-built to operationalize AI governance, automate compliance workflows, and manage AI records from submission through final disposition — with full audit-ready documentation at every step.

Governance Workflow

SubmissionRisk AssessmentPrivacy ReviewRecordsLegal ApprovalDecision

AI Use Case Intake

Smart intake with conditional logic, real-time PII detection, and automated regulatory trigger identification.

Risk Scoring Engine

Live five-dimension risk scoring with automated action recommendations and escalation thresholds.

Privacy Review Workflow

Automated PII routing to privacy officers with structured review queues and PIA generation.

Records Management Engine

Automatic NARA classification, OCR extraction, retention labeling, RMSA self-assessment, and destruction workflow.

Policy & Control Library

Centralized repository of AI governance policies and regulatory controls mapped to federal frameworks.

Audit Log & Reporting

Immutable audit trail capturing every action, decision, and timestamp for IG and compliance review.

Approval Workflow Engine

Multi-stage approval routing: Submission → Risk → Privacy → Records → Legal → Decision.

Executive Dashboard

Real-time visibility into governance posture, risk exposure, and compliance status across all AI use cases.

Free Resource

KNOW WHERE YOU STAND
BEFORE A REGULATOR
TELLS YOU.

Get the free CGS AI Governance Readiness Checklist — 20 questions mapped directly to federal standards. Identify your gaps before an audit does it for you.

Used by governance leaders across federal, healthcare, and defense sectors.

Your information is kept confidential.

Our Strategic Advantage

THE METHODOLOGY
THAT CONNECTS
EVERYTHING.

Organizations working with CGS gain a governance methodology that connects AI innovation, regulatory compliance, operational risk management, and public transparency into a single coherent structure.

This allows organizations to adopt advanced technologies with confidence while protecting their reputation, legal standing, and long-term operational integrity.

AI Innovation

Deploy advanced AI with governance built in from day one.

Regulatory Compliance

Stay ahead of federal and sector-specific standards.

Operational Risk Mgmt

Identify and mitigate risk before it becomes exposure.

Public Transparency

Build lasting trust with the public and regulators.

Let's Work Together

READY TO CLOSE
THE GOVERNANCE
GAP?

Organizations implementing AI must balance innovation with responsible governance. CGS helps organizations build the governance structures needed to deploy AI responsibly, confidently, and in compliance with regulatory requirements.

Federal AI governance expertise
NIST AI RMF alignment
FOIA & privacy compliance specialists
Fixed-fee entry points available
15+ years federal experience

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