Applied Transformation · Process, Tech & People

Power is nothing without control.

Memorandum

Most AI failures are governance failures wearing a tech costume.

Sixteen DACH engagements. Three structural problems. None of them technical. Open citation, monthly updates.
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427 days · enforcement

EU AI Act Article 6 obligations begin 02.08.2026.

Annex III classifications in scope. Max fine €35M or 7% of global revenue. No grace period. Self-declaration is not a defence.
Compliance window →
Field study · n=16

14 of 16 estates have no central AI inventory.

The structural problems repeat across DACH enterprises — and they are not technical. Read the full pattern frequency.
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Practice

A 90-minute diagnostic. No deck. One page in writing.

By appointment. Selected engagements through 2026. Languages EN · DE · IT. Diagnostic is offered without fee.
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01 / POSITION

The structural problems repeat. They are not technical.

The question is rarely "was the model wrong?" — it is who owned this, against which classification, with what documentation. Sixteen DACH engagements. Five recurring gaps, each tied to a specific article of the EU AI Act.

14 / 16
have no central AI inventory.
Article 11
15 / 16
have no real Article 4 literacy programme.
Article 4
11 / 16
rely on a vendor-asserted classification.
Annex III
09 / 16
have no executive owner of record.
Article 26
16 / 16
operate without post-market monitoring.
Article 72
02 / DISCIPLINES

Three lanes of work.

Engagements are scoped against one of three disciplines, or as a coordinated programme across all three.

§ 01 · Discipline

Compliance Readiness

EU AI Act gap analysis, Annex III classification, conformity preparation, and post-market monitoring under Article 72. Audit-ready artifacts as the deliverable.
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§ 02 · Discipline

Governance Architecture

Centres of Excellence, Article 4 literacy at scale, shadow-AI registers and vendor frameworks with downstream allocation. Designed to survive a board change.
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§ 03 · Discipline

Strategic Advisory

Use-case portfolio, board briefings, regulatory horizon scan, AI Act / ISO 42001 / NIST cross-walk. Counsel sits next to engineering, not above it.
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04 / OPERATOR

Alessandro Cancemi.

Alessandro Cancemi
Alessandro Cancemi

Six years of regulated greenfield at Bayer AG — strategy, portfolio governance, vendor frameworks and literacy programmes — under SOX, GxP and audit. Practice in formation 2025. Opens 2027.

04 / BEGIN · 427 DAYS TO ENFORCEMENT

A 90-minute diagnostic.
No deck. No pitch.
One page in writing.

By appointment. Selected engagements through 2026. Languages EN · DE · IT. The diagnostic is offered without fee.

→
Cancemi.