BLACKSWANCapital Markets OS Approval & Sign-Off Workflow · v1.0 draft ← Return to OS Architecture
Approval & Sign-Off · Founder-only staging

Approval & Sign-Off Workflow Turns the Production Go/No-Go decision into named accountable approvals with conditions, evidence references, expiry dates, and an escalation path.

This workflow is internal sign-off evidence. An "Approved" state on this page never means regulatory approval, legal advice, an audit opinion, or authorization to launch — it means a named BLACKSWAN owner has accepted the linked evidence pack for the scope shown. Production cutover still requires Microsoft Entra OIDC with Conditional Access, RBAC/ABAC, server-side session issuance, and SIEM-forwarded audit events.

Required sign-offs
29
across 7 scopes
Founder, CCO, Risk, CISO, COO, Legal, Board.
Approved · current
6
Approved
Confined to Internal & Founder/Admin Production.
Conditional · pending evidence
8
Conditional
Amber gates with named owner and review date.
Blocked · cannot proceed
15
No-Go
Counterparty Data Room, External Pilot, Full Launch.
Filter by state Approved Conditional Rejected · No-Go Pending Risk-Accepted Expired Escalated
Approval states used on this workflow
Pending
Review in flight; evidence pack assigned to a named owner; no decision yet.
Approved
Owner has accepted the evidence pack and signed for the named scope.
Approved with Conditions
Owner has accepted with explicit limitation text, expiry, and monitoring control.
Rejected · No-Go
Owner has rejected the scope; evidence pack uplift required before re-submission.
Risk-Accepted
Residual risk accepted by approver for a tightly-scoped, monitored pilot.
Expired
Approval lapsed at its review date; treat as Pending until renewed with fresh evidence.
Escalated
Approver could not decide within SLA; routed to Founder Admin and Board observer.
Eight approval stages

Each stage names an owner and an evidence pack

No stage can be skipped. A stage is only complete when the linked evidence pack has been accepted by the named owner with an approver signature recorded on the Pack Registry. Stage state below reflects the current Production Go/No-Go posture.

Stage 1 · Draft Decision Approved
Founder Admin drafts the launch decision per scope
Captures recommended state per scope, jurisdiction implications, and gates referenced. Output is the v1.0 Go/No-Go memo on the Pack Registry.
Owner
Founder Admin
Last reviewed
2026-05-15
Stage 2 · Evidence Review Conditional
Compliance verifies linked evidence packs are current
Compliance Owner re-checks pack hashes, expiry dates, limitation text, and recipient ledger evidence. Conditional pending Data-Room MNPI policy-version binding and Control Testing operating-effectiveness samples.
Owner
Chief Compliance Officer
Last reviewed
2026-05-15
Stage 3 · Risk & Compliance Challenge Conditional
Risk Owner and CCO challenge residual risks per scope
Outsourcing concentration, settlement responsibility, MNPI policy binding, and partner-route assurance are challenged with reviewer trail. Risk-Accepted Pilot evidence captured where used.
Owner
Risk Owner · CCO · MLRO observer
Last reviewed
2026-05-14
Stage 4 · Security/Ops Readiness Rejected
CISO and COO confirm cutover/rollback readiness
Entra OIDC tenant application not registered; SIEM forwarding staging-only; cutover/rollback runbook draft. Rejected for any external scope until Gate 6 closes.
Owner
CISO · COO
Last reviewed
2026-05-12
Stage 5 · Legal/Regulatory Counsel Review Pending
External counsel opinion on activity perimeter per jurisdiction
ADGM/FSRA perimeter draft circulated; UK FCA, MAS, MiFID/MiFID II perimeter opinions outstanding. No supervisor pre-engagement record on file for UK/MAS/EEA.
Owner
Legal / Regulatory Counsel
Last reviewed
2026-05-10
Stage 6 · Board/Founder Approval Conditional
Board resolution for any external scope; Founder for internal scopes
Founder approval recorded for Internal Production and Founder/Admin Production scopes only. Board resolution outstanding for Counterparty Data Room, Controlled External Pilot, Full External Launch.
Owner
Founder/CEO · Board
Last reviewed
2026-05-15
Stage 7 · Release Authorization Blocked
Final release authorization for the named scope
Blocked for any external scope while P0 blockers remain open. Release authorization available only for Internal Production and Founder/Admin Production via the Release panel below.
Owner
Founder Admin
Last reviewed
2026-05-15
Stage 8 · Post-Launch Review Pending
30-day post-launch evidence refresh and limitation revalidation
Triggered automatically 30 days after any GO or Risk-Accepted Pilot release. Includes incident retrospective, monitoring evidence, and limitation-text re-attestation.
Owner
Founder Admin · CCO
Last reviewed
—
Sign-off matrix · scope × role

Current state per approver, per launch scope

Cells show the current internal sign-off state. None of these states imply supervisor authorisation. Approvals required-but-pending block the scope from progressing past Stage 7.

Approved Conditional No-Go Pending Risk-Accepted Not required
Approver role Internal Production Founder/Admin Production Board Preview Regulator Prep Counterparty Data Room Controlled External Pilot Full External Launch
Founder / CEO Approved Approved Conditional Conditional No-Go No-Go No-Go
Compliance Owner (CCO / MLRO) Not required Approved Conditional Risk-Accepted No-Go No-Go No-Go
Risk Owner (CRO / Risk Governance) Not required Approved Conditional Risk-Accepted No-Go No-Go No-Go
Engineering / Security Owner (CISO) Approved Conditional Not required Not required No-Go No-Go No-Go
Operations Owner (COO / Post-Trade) Not required Approved Not required Not required Pending Pending Pending
Legal / Regulatory Counsel Not required Not required Pending Pending Pending Pending Pending
Board / Independent Reviewer Not required Not required Risk-Accepted Risk-Accepted Pending Pending Pending
Evidence reference panel

Sign-offs linked to 21 evidence packs and six production gates

Every approval on this surface references a pack on the Pack Registry and a Launch Readiness gate. Stale or missing evidence appears in the right column and blocks the linked approval until refreshed.

Current evidence

Linked packs accepted by their named owner within the review window.

  • Auth · Gate 1 Foundation · CISO accepted 2026-05-15
  • Policy Attestation · Gate 1 Foundation · Compliance accepted 2026-05-15
  • Board-Pack Attestation · Gate 5 Stakeholder Bundle · Founder + Board Liaison accepted 2026-05-15
  • Conduct Risk MI · Gate 5 Stakeholder Bundle · Risk Gov. accepted 2026-05-15
  • Regulatory Exam Response · FSRA · Gate 5 Stakeholder Bundle · Regulatory Affairs accepted 2026-05-15
  • Incident · Gate 3 Operational Resilience · Internal tabletop evidence accepted 2026-05-14

Stale / missing evidence

Packs whose state blocks linked sign-offs. Each requires a fresh evidence release before its row can move to Approved.

  • Product Governance · Gate 2 · target market, launch gates, distribution restrictions OPEN
  • Model Risk · Gate 2 · validation pack and monitoring thresholds INCOMPLETE
  • Outsourcing Concentration · Gate 3 · service map, exit plans, fallback providers OPEN
  • Activity Perimeter · UK / MAS / EEA · Gate 4 · external counsel opinions OUTSTANDING
  • Entra OIDC cutover · Gate 6 · tenant application NOT REGISTERED, SIEM forwarding STAGING-ONLY
  • Data-Room MNPI Access · Gate 2 · policy-version binding PENDING
  • Settlement Responsibility · Gate 3 · four-eye approval + partner SLA mapping OPEN
  • Control Testing · Gate 2 · operating-effectiveness samples PARTIAL
  • Revenue Recognition / Tax-VAT · Gate 5 · auditor pre-clearance + place-of-supply analysis OUTSTANDING
  • KYC / KYB Onboarding · MAS · Gate 2 · Notice 626 alignment evidence OUTSTANDING
  • Partner-Route Assurance · MAS · Gate 3 · MAS-licensed partner appointment letter MISSING
  • Capital / Liquidity Readiness · Gate 3 · ICAAP/ICARA-style write-up NOT BOARD-APPROVED
  • Regulatory Digital Twin Decision · Gate 4 · supervisor sharing NOT AUTHORISED
  • Regulatory Change · Gate 4 · impact-engine routing to evidence packs PARTIAL
  • Complaints · Gate 4 · written policy and intake route DOCUMENTED · risk-accepted to 2026-08-31
Conditional approval terms

Every conditional state names its limitation, expiry, owner, monitoring control, rollback trigger, and external-use restriction

A conditional or risk-accepted approval is only valid while every field below is current. If the review date passes, the approval auto-expires; if the monitoring control fires, the rollback trigger pulls the scope back to No-Go.

Internal Production Conditional
Limitation
Founder Admin and named internal users only. No external surface, no regulator-shared bundle.
Expiry
2026-07-15 · 60-day auto-expiry; reissue requires fresh evidence pack release.
Owner
Founder/CEO; CISO co-sign required.
Monitoring
SIEM rule on auth, MNPI access, outsourcing route anomalies.
Rollback
Pull scope to No-Go on any P0 detection; revoke Founder Admin session.
External use
None. Any export attempt blocked at distribution gate.
Founder/Admin Production Conditional
Limitation
Founder-only operations against production-flagged surfaces; MFA evidence and immutable audit trail end-to-end.
Expiry
2026-07-15 · 60-day auto-expiry; conditional on Entra cutover progress at next review.
Owner
Founder/CEO; CCO and CISO co-sign required.
Monitoring
SIEM rule on auth, session anomalies, evidence-export anomalies.
Rollback
Auto-revert to Internal Production on any P0; revoke session and notify Board observer.
External use
None. Any external distribution blocked by Stakeholder Bundle gate.
Board Preview Risk-Accepted Pilot
Limitation
Watermarked Board pack distributed to named directors; recipient ledger and reviewer trail evidenced; no regulator-shared distribution.
Expiry
2026-07-15 · 60-day auto-expiry; tied to Board cadence review.
Owner
Founder/CEO; Board Liaison co-sign; Board observer present.
Monitoring
Token-access attempt anomaly triage; recipient exception ledger.
Rollback
Recall watermarked pack on any recipient exception or distribution gate breach.
External use
Named director cohort only. No counterparty or regulator distribution.
Regulator Prep Risk-Accepted Pilot
Limitation
Internal-only response binders, exam-response packs, and supervisor pre-engagement rehearsal. No regulator-shared distribution yet.
Expiry
2026-07-15 · 60-day auto-expiry; aligned to FSRA cadence.
Owner
CCO; Regulatory Affairs co-sign; Legal/Regulatory Counsel observer.
Monitoring
FSRA bundle scope drift detection; UK/MAS/EEA perimeter change events.
Rollback
Suspend supervisor pre-engagement if perimeter changes; reissue limitation text.
External use
FSRA only when authorised. UK/MAS/EEA remain internal-only until perimeter green.
Counterparty Data Room Rejected
Limitation
Blocked. MNPI rooms not bound to current policy version; cannot distribute to external counterparties.
Expiry
n/a · no approval issued.
Owner
CCO; CISO co-sign required when re-submitted.
Monitoring
n/a until conditional approval reinstated.
Rollback
n/a.
External use
None. Reactivation requires Data-Room MNPI Access pack uplift.
Controlled External Pilot Rejected
Limitation
Blocked. Jurisdiction Readiness gate red across all four jurisdictions.
Expiry
n/a · no approval issued.
Owner
Board resolution required when re-submitted.
Monitoring
n/a until conditional approval reinstated.
Rollback
n/a.
External use
None. Reactivation requires at least one jurisdiction perimeter green and partner-route assurance attached.
Escalation queue

Items routed to Founder Admin and Board observer

An item enters the queue if a P0/P1 blocker is unresolved, an approval has expired, evidence has been challenged in a reviewer round, counsel review is missing, or the last-reviewed date has slipped past SLA.

P0 P1 Expired Challenged
Severity
Item
Owner
Aging
P0
Product Governance route not closed for external use Blocks Stage 2 Evidence Review for Counterparty Data Room and all external scopes.
Product Gov.
5d open
P0
Model Risk validation pack and monitoring thresholds incomplete Blocks Stage 3 Risk & Compliance Challenge for any quantitative-model-using scope.
Model Risk
7d open
P0
Outsourcing Concentration · service map and exit plans open Blocks Stage 4 Security/Ops Readiness for all scopes; supervisor outsourcing notice cannot be filed.
Risk Gov.
8d open
P0
Microsoft Entra OIDC cutover application not registered Blocks Stage 4 Security/Ops Readiness and Stage 7 Release Authorization for any external scope.
CISO · IAM
4d open
Challenged
UK FCA / MAS / MiFID-II perimeter counsel opinion outstanding Stage 5 Legal/Regulatory Counsel Review pending across three jurisdictions; routed to Founder Admin and Board observer.
Legal · Reg. Affairs
5d open
P1
Data-Room MNPI Access policy-version binding pending Limits Counterparty Data Room re-submission; affects Stage 2 Evidence Review reviewer trail.
CCO · CISO
3d open
P1
Settlement Responsibility four-eye approval not closed External responsibility routes lack four-eye approval and partner SLA mapping.
Post-Trade Ops
6d open
Stale
FSRA exam-response rationale last reviewed beyond SLA Last reviewer pass was inside SLA at 2026-05-15; will auto-expire on 2026-07-14 unless re-attested.
Reg. Affairs
SLA 60d
Audit trail · decision history

Every state change is timestamped, named, rationale-bound, and evidence-linked

Sample audit lines consistent with the current staging posture. Entries are simulated/staging evidence; production audit-event capture still requires SIEM-forwarded audit events under Microsoft Entra OIDC.

Timestamp
Approver
Action & rationale
Evidence ref
2026-05-15 06:14Z
Founder / CEO
Approved Internal Production; founder MFA evidence current; SIEM forwarding rule active on auth and MNPI access. Conditional on 60-day review.
pack/auth#hash:9a2c…
2026-05-15 06:32Z
CISO
Co-signed Internal Production; identity model documented; audit-event capture verified for sign-in, evidence release, approver actions.
pack/auth#hash:9a2c…
2026-05-15 09:01Z
CCO
Approved Founder/Admin Production with conditions; Entra cutover deferred to next review; rollback trigger registered.
pack/policy-attestation#hash:7e11…
2026-05-15 11:48Z
Board Liaison
Risk-Accepted Pilot for Board Preview; watermarked recipient ledger active; reviewer trail captured.
pack/board-pack-attestation#hash:bc40…
2026-05-15 13:22Z
Regulatory Affairs
Risk-Accepted Pilot for FSRA Regulator Prep; bundle scope agreed; UK/MAS/EEA remain internal-only.
pack/regulatory-exam-response#hash:5d8f…
2026-05-14 16:05Z
Risk Owner
Challenge round: Settlement Responsibility and MNPI policy binding deferred to next reviewer pass; Conditional applied.
pack/settlement-responsibility#hash:1f73…
2026-05-12 10:11Z
Product Governance
Rejected external use; target market and distribution restrictions remain open across jurisdictions.
pack/product-governance#hash:38ab…
2026-05-10 08:42Z
Model Risk
Rejected production model use; validation pack and monitoring thresholds incomplete.
pack/model-risk#hash:c2e9…
2026-05-09 14:28Z
Risk Governance
Rejected external scope; outsourcing concentration map, exit plans, and fallback providers remain open.
pack/outsourcing-concentration#hash:0b6d…
Final release authorization

Disabled for any external scope until P0 blockers are closed

The Release Authorization button is intentionally inert here; this is staging. Production release authorization will be issued only when every required sign-off is Approved (or Approved with Conditions) and every P0 blocker is closed.

Internal Production · Founder/Admin Production
Conditional Release
Conditional
All required approvals are Approved or Approved with Conditions. Founder/CEO and CISO co-sign on file. SIEM monitoring active. 60-day auto-expiry registered. This panel is staging-only; actual production release authorization is issued out-of-band by Founder Admin.
Expires 2026-07-15 Rollback ready
Counterparty Data Room · Controlled External Pilot · Full External Launch
Blocked · No-Go
Blocked
Seven P0 blockers open; four of six Launch Readiness gates not closed; jurisdiction states red for UK FCA, MAS, MiFID/MiFID II; Stage 4 Security/Ops Readiness rejected; Stage 5 Legal/Regulatory Counsel Review pending. Release authorization is unavailable.
P0 open · 7 Gates not closed · 4 of 6 Re-decision 2026-07-15
Printable decision memo · preview

Board/Regulator-ready structured memo · internal-only draft

Captures the named sign-offs and the conditions that bound them. Internal-only until Stakeholder Bundle distribution evidence is on file. Use the browser's Print menu to produce a clean PDF (no script run is required).

Approval & Sign-Off memo · v1.0 draft · founder-only staging

Decision summary
Conditional Release for Internal Production and Founder/Admin Production; Risk-Accepted Pilot for Board Preview and Regulator Prep · FSRA; No-Go for Counterparty Data Room, Controlled External Pilot, and Full External Launch.
Scope
Founder Admin and named internal users; Board preview limited to a watermarked recipient cohort. No external counterparty, no regulator-shared distribution beyond FSRA pilot evidence.
Sign-offs on file
Founder/CEO (Internal, Founder/Admin, Board Preview, Regulator Prep); CCO (Founder/Admin Conditional, Board Preview Conditional, Regulator Prep Risk-Accepted); Risk Owner (Founder/Admin Approved, Board Preview Conditional, Regulator Prep Risk-Accepted); CISO (Internal Approved, Founder/Admin Conditional); COO (Founder/Admin Approved).
Sign-offs outstanding
Legal/Regulatory Counsel Stage 5 for all four external scopes; Board resolution for Counterparty Data Room, Controlled External Pilot, Full External Launch; Operations Owner for external scopes; CISO for external scopes.
Conditions
60-day auto-expiry across all conditional and risk-accepted states; SIEM monitoring on auth, MNPI, outsourcing-route anomalies; rollback trigger pulls scope to No-Go on any P0 detection; external use restricted to FSRA pilot evidence only.
Residual risks
External-bundle distribution before Product Governance closes; production model use without validation pack; outsourcing concentration without exit plan; unauthorised activity in UK/MAS/EEA; staging-only Entra OIDC; MNPI without policy-version binding; settlement responsibility ambiguity.
Re-decision date
2026-07-15 · 60-day automatic expiry on Conditional and Risk-Accepted Pilot states; reissue requires fresh evidence release and a new memo.
Limitations
This memo is internal sign-off evidence. It is not legal advice, not regulatory approval, not an audit opinion, and not authorization to launch any regulated activity. Regulated activity remains simulated, partner-routed, locked, or production-regulated as defined in the OS Architecture, Completeness Command Centre, Launch Readiness Command Centre, and Production Go/No-Go Board. No real issuer, investor, KYC, MNPI, order-book, custody, or settlement data is enabled.

Change Freeze, Release Approval & Rollback Evidence Gate

Internal release-control readiness posture only. The release-approval chain mirrored here is captured against the named release candidate / release window in the Release Control & Rollback Centre. Production launch requires CAB + Board + Compliance (CCO + MLRO + Legal) + Risk (CISO + CFO) sign-offs, plus deployment evidence, CI/CD provenance, rollback plan + rehearsed drill, dependency freeze, post-release monitoring, incident bridge readiness, communications, and a captured go-live authority counter-sign. Staging or demo deployment does not count as production release evidence. No deploy token, CI/CD secret, signing key, registry credential, production deploy log line, rollback credential, kill-switch admin key, feature-flag admin token, post-release log line, customer data, incident bridge URL, regulator/board release notification channel, or live release credential is exposed by this Workflow, the API at /api/release-approval-rollback-evidence, the fixture, or any commit.

Controls assessed
28

Release candidate · freeze · window · sign-offs · deployment · CI/CD · rollback · DB · flags · dependency freeze · monitoring · bridge · comms · authority

Ready · internal
0

Owner + approver + approval + evidence + (where applicable) rollback drill captured

Approval pending
28

CAB · Board · Compliance · Risk · Founder Office counter-sign not yet captured

Rollback rehearsal untested
5

Rollback / DB rollback / kill-switch drill not in freshness window

Evidence missing
2

Manifest · sign-off · dependency lock · comms record not linked

Rollback blocked
8

Rollback plan + drill + DB rollback + flag/kill-switch not all approved & evidenced

Post-release monitoring
1

Post-release monitoring window not declared / approved / evidenced

Production launch
HOLD · NO-GO

Until release candidate + freeze + window + sign-offs + deployment + CI/CD + rollback + drill + DB + flags + dependency freeze + monitoring + bridge + comms + authority captured

Authoritative row table is rendered in the Release Control & Rollback Centre. Mirrored summaries in the Final Production Launch Control Tower, the Production Go/No-Go Board, the Production Monitoring & Incident Command Centre, the Programme Governance & Roadmap Centre, and the Completeness Command Centre. Read-only fixture exposed via /api/release-approval-rollback-evidence; cross-references /api/production-config-readiness, /api/production-ingress-route-readiness, /api/secret-rotation-key-custody, /api/backup-restore-recovery-evidence, /api/observability-slo-incident-evidence, /api/entra-oidc-readiness, /api/evidence-pack-gate-validation, and /api/jurisdictional-permissions-matrix. No deploy token, CI/CD secret, signing key, registry credential, production deploy log line, rollback credential, kill-switch admin key, feature-flag admin token, post-release log line, customer data, incident bridge URL, regulator/board release notification channel, or live release credential is returned from any endpoint. Internal release-control readiness posture only · not security certification · not regulatory approval · not external endpoint authorisation · not external-use authorisation. Staging or demo deployment does not count as production release evidence.

§Authority · Counsel, Compliance & Board Approval Authority Register

Counsel · Compliance · Board approval-authority map — internal posture only

Holds every approval-dependent gate (production launch, regulator submission, external bundle release, incident escalation, CAB / production change, go-live counter-sign) at HOLD · NO-GO until each required approval-authority control — internal & external Counsel authority, Compliance / CCO authority, MLRO / financial crime authority, Risk Committee authority, CISO / security authority, CFO / finance authority, Board / Audit Committee / Risk Committee authority, Founder Office authority, go-live counter-sign authority, regulator-submission counter-sign authority, external bundle release counter-sign authority, incident escalation authority, production change / CAB authority, delegated authority matrix, approval expiry / recertification rule register, and escalation / override path register — is captured with owner + named forum / approver class descriptor + approval state + evidence reference + quorum / signature rule + delegated authority reference + expiry / recertification rule + escalation path + last-reviewed date. Staging or demo acknowledgements, founder-only rehearsal sign-offs, simulated board walkthroughs, fixture-only counsel reviews, internal demo quorum readings, and sandbox e-signature rehearsals do not count as production approval authority. No Counsel name, External Counsel name, Compliance / CCO / MLRO name, Risk Committee member identity, CISO / CFO name, Board / observer identity, board pack body, board minute body, board resolution body, board meeting link, attendee identity, signature image, signature hash, e-signature token, approval token, delegated authority instrument body, power-of-attorney body, board secretariat email, private board distribution channel, privileged legal advice text, privileged work-product, external counsel memo body, customer data, MNPI, or live approval-token timer appears in this Workflow, fixture, API, or commit.

Controls assessed
19

Counsel · Compliance · CCO · MLRO · Risk Cttee · CISO · CFO · Board · Founder Office · go-live · regulator-submission · external bundle release · incident escalation · CAB · delegation · expiry · escalation

Ready · internal
0

Owner + forum + class descriptor + approval + evidence + quorum / signature rule + delegation + expiry + escalation captured

In review
0

Item partially captured (forum / quorum / signature / delegation / expiry / escalation / evidence in flight)

Missing · blocked
0

Required approval-authority evidence not supplied / explicitly blocked pending upstream dependency

Approval pending
0

Counsel · External Counsel · CCO · MLRO · Risk Cttee · CISO · CFO · Board · Founder Office · Regulatory Affairs · Secretariat · CAB counter-sign not yet captured

Quorum unverified
0

Chair + minimum class descriptors + observer rule missing / unbound / not satisfied

Signature rule missing
0

Four-eye / three-counter-sign / minuted Board resolution / e-signature standard reference not captured

Delegation unverified
0

Delegate class descriptor / scope limit / expiry / revocation path not bound to controlled instrument reference

Expiry unset
0

Annual / bi-annual / per-release / on-change recertification rule not captured

Escalation unmapped
0

Chair → committee → board → founder office → external counsel path not bound to controlled register reference

Production launch · approval
HOLD · NO-GO

Until Counsel + Compliance + CCO + MLRO + Risk Cttee + CISO + CFO + Board + Founder Office + go-live + CAB + delegation + expiry + escalation captured

External release · approval
HOLD · NO-GO

Until Counsel + CCO + Founder Office + Audit Committee + Stakeholder Liaison counter-sign rule + delegation + expiry + escalation captured

Regulator submission · approval
HOLD · NO-GO

Until Counsel + CCO + MLRO + Founder Office + Audit Committee + Regulatory Affairs counter-sign rule + delegation + per-submission expiry + escalation captured

Read-only fixture exposed via /api/approval-authority-register; reference NAMES, ownership, approval forum names, approver class descriptors (e.g. "Counsel · external", "CCO · group", "Board · Audit Committee"), approval state, evidence reference IDs, quorum / signature rule class descriptors, delegated authority class descriptors, expiry / recertification rule class descriptors, escalation path class descriptors, linked gate / control / evidence-pack dependency endpoint paths, launch impact text, external-use impact text, and unlock criteria only. Cross-references the Change Freeze, Release Approval & Rollback Evidence Gate, the Regulatory Notification & Board Escalation Centre, the Stakeholder Rooms & Evidence Distribution Centre, the Evidence-Pack Gate Validation, the Jurisdictional Permissions Matrix, the Board Pack · Investor Narrative · Strategic Reporting Centre, the Final Production Launch Control Tower, the Programme Governance & Roadmap Centre, and the Completeness Command Centre. No Counsel name, External Counsel name, Compliance / CCO / MLRO name, Risk Committee member identity, CISO / CFO name, Board / observer identity, board pack body, board minute body, board resolution body, board meeting link, attendee identity, signature image, signature hash, e-signature token, approval token, delegated authority instrument body, power-of-attorney body, board secretariat email, private board distribution channel, privileged legal advice text, privileged work-product, external counsel memo body, customer data, MNPI, or live approval-token timer is returned from any endpoint. Internal approval-authority readiness posture only — not Counsel approval, not Compliance / CCO / MLRO sign-off, not Risk Committee resolution, not CISO / CFO sign-off, not board approval, not quorum determination, not signature rule satisfaction, not delegated authority grant, not board minute, not board countersign, not go-live authorisation, not regulator-submission release authority, not external bundle release authority, not incident escalation authority, not production change / CAB authority, and not external-use authorisation. Staging or demo acknowledgements do not count as production approval authority.

Authority control Group Approval forum Approver class Quorum / signature Delegation Expiry Escalation State Unlock
Loading approval-authority readiness fixture…
§Risk · Production Risk Acceptance & Exception Register

Risk-exception readiness map — internal posture only

Holds every exception-dependent gate (production launch, regulator submission, external bundle release, incident escalation, CAB / production change, go-live counter-sign, partner-route activation, secret rotation) at HOLD · NO-GO until each required risk-exception control — Entra OIDC transition exception, jurisdictional permission limitation, evidence-pack metadata exception, external-bundle release limitation, regulator-submission limitation, backup / restore readiness exception, observability / SLO exception, release / rollback exception, approval-authority exception, partner-route / mTLS readiness exception, secret / key custody exception, production config missing exception, data / MNPI boundary exception, incident escalation exception, and go-live authority exception — is captured with owner + approver class descriptor + approval forum + approval state + evidence reference + limitation text + compensating control + expiry + review cadence + escalation path + last-reviewed date. Staging or demo acknowledgements, founder-only rehearsal waivers, simulated board exception walkthroughs, fixture-only counsel exception reviews, internal demo authority readings, and sandbox e-signature rehearsals do not count as production risk acceptance. Risk acceptance never overrides an unresolved P0 blocker without explicit authority evidence and limitation language. No approver name, approver email, approver signature, board minute, board meeting link, board resolution body, exception token, e-signature token, private risk-memo body, privileged legal advice text, privileged work-product, external counsel memo body, customer data, MNPI, live deploy credential, regulator submission body, partner credential, signed-URL secret, OTP code, watermark salt body, IP address, device fingerprint, or live notification channel appears in this Workflow, fixture, API, or commit.

Exceptions assessed
15

Identity · jurisdiction · evidence-pack · external bundle · regulator submission · backup · observability · release · approval-authority · partner-route · secret custody · config · data/MNPI · incident · go-live

Ready · internal
0

Owner + authority + limitation + compensating control + evidence + expiry + review cadence + escalation captured

In review
0

Exception partially captured (owner / authority / limitation / compensating control / evidence / expiry / cadence / escalation in flight)

Not accepted
0

Default state. Required risk-exception evidence not supplied or risk acceptance explicitly not accepted

Blocked
0

Exception explicitly blocked pending upstream Counsel · CCO · MLRO · Risk Cttee · CISO · CFO · Board · Founder Office · CAB dependency

Expired
0

Expiry / per-release rule passed without recertification — reverts to HOLD · NO-GO

Expiry missing
0

30-day / 90-day / quarterly / per-release / on-change review cadence not captured

Owner missing
0

Owner class descriptor not captured

Authority missing
0

Approver class descriptor + approval forum + approval state not captured

Limitation missing
0

Limitation text (what the exception does NOT cover) not captured

Compensating control missing
0

Compensating control text not captured / not bound to controlled register reference

Evidence missing
0

Exception memo / charter / board minute reference / compensating control reference not linked

Production · risk acceptance
HOLD · NO-GO

Until owner + authority + limitation + compensating control + evidence + expiry + review cadence + escalation captured for every required exception

External use · exception
HOLD · NO-GO

Until required external-use exceptions are ready-internal (Counsel + CCO + Founder Office + Board · Audit Committee + Stakeholder Liaison counter-sign)

Regulator submission · exception
HOLD · NO-GO

Until Counsel + CCO + MLRO + Founder Office + Board · Audit Committee + Regulatory Affairs counter-sign + per-submission expiry captured

Read-only fixture exposed via /api/risk-acceptance-exception-register; reference NAMES, ownership, approver class descriptors, approval forum names, approval state, evidence reference IDs, limitation text, compensating control text, expiry / review cadence rule class descriptors, escalation path class descriptors, linked gate / control / evidence-pack dependency endpoint paths, launch impact text, external-use impact text, and unlock criteria only. Cross-references the Counsel, Compliance & Board Approval Authority Register, the Regulatory Submission & Supervisory Correspondence Evidence Gate, the Stakeholder Evidence Distribution & External Bundle Release Gate, the Change Freeze, Release Approval & Rollback Evidence Gate, the Evidence-Pack Gate Validation, the Jurisdictional Permissions Matrix, the Strategic Risk Register & Scenario Planning Centre, the Final Production Launch Control Tower, the Production Go/No-Go Board, the Regulatory Notification & Board Escalation Centre, the Programme Governance & Roadmap Centre, and the Completeness Command Centre. No approver name, approver email, approver signature, board minute, board meeting link, board resolution body, exception token, e-signature token, private risk-memo body, privileged legal advice text, privileged work-product, external counsel memo body, customer data, MNPI, live deploy credential, regulator submission body, partner credential, signed-URL secret, OTP code, watermark salt body, IP address, device fingerprint, or live notification channel is returned from any endpoint. Internal risk-exception readiness posture only — not risk acceptance, not legal/compliance exception, not board waiver, not counsel approval, not regulator acceptance, not production approval, not go-live approval, not external-use waiver, and not temporary workaround approval. Staging or demo acknowledgements do not count as production risk acceptance. Risk acceptance never overrides an unresolved P0 blocker without explicit authority evidence and limitation language.

Exception Category Owner Authority Limitation Compensating control Expiry · cadence Escalation State Unlock
Loading risk-exception readiness fixture…
§ Manifest Approval Workflow & Export Request Queue (mirror)

Internal class-descriptor approval queue · expected external release HOLD · NO-GO

HOLD · NO-GO

Mirror of the Manifest Approval Workflow & Export Request Queue summary exposed via /api/manifest-approval-workflow-export-request-queue. Class-descriptor index of approval phases, required dependency-gate classes, and blocker rollups. Never an export, never a release, never a transmission. Never resolves real recipients. Never overrides any blocker.

Queue items · classes
4
internal: board-prep · regulator-prep · investor-narrative-prep · operational-readiness-review
Blocked from external bundle
4
External transmission never permitted at current posture
Approval phases · classes
5
intake · gate-eval · rehearsal · accept · hold
Overall external release
HOLD · NO-GO
Queue never overrides Production Standby

Posture invariants returned: productionPosture='HOLD · NO-GO', externalReleasePosture='HOLD · NO-GO', overridesAnyBlocker=false, performsActualExport=false, externalTransmissionPermitted=false.

Assumptions and limitations

This Approval & Sign-Off Workflow is internal sign-off evidence. It is explicitly not:

All regulated activity on the platform remains simulated, partner-routed, locked, or production-regulated as defined in the OS Architecture and Completeness Command Centre. Production cutover still requires Microsoft Entra OIDC with Conditional Access, RBAC/ABAC, server-side session issuance, and SIEM-forwarded audit events. Items shown on this Workflow are plausible sample states consistent with the existing Launch Readiness Command Centre and Production Go/No-Go Board; live values will be sourced from the Pack Registry once the cutover is signed off.