The org chart arrives Wednesday morning.
Not the full chart. A redacted version, four names blacked out under a procurement confidentiality clause that does not apply to this request. I note the clause number. I will contest it later.
But the Interim Procurement Director position is unredacted.
It was held, during the relevant period — the period when fourteen pages of licensing rows were marked pending and waved through intake without legal review — by a person who was simultaneously serving as Regulatory Liaison for the division's AI Audit function.
One person. Two roles.
I read this sentence twice.
I have worked in this field for nine years. I have read procurement documents the way other people read novels — for character, for what the gaps reveal about the person who designed the structure. Most of what I find is negligence: someone who did not read the form, someone who trusted a subordinate, someone who moved too fast because the timeline was aggressive and their supervisor was not asking questions.
This is not that.
The Regulatory Liaison role for an AI Audit function exists for one purpose: to ensure that AI procurement complies with the provisions of the AI Provenance Act. The person in that role is not a generalist. They are not someone who might not know what pending means in a licensing manifest. They are the person the Act designates to know.
The Interim Procurement Director marked fourteen pages pending.
The Regulatory Liaison had a professional obligation to flag them.
They were the same person.
I file the org chart under Section 9 supporting materials, cross-referenced to the manifest acquisition audit log. The two documents together describe something specific: not confusion, not negligence, not an overburdened team under deadline pressure. They describe a person who knew what the rows meant, who had a legal obligation to act on that knowledge, and who chose not to.
I call the special investigations unit and reach voicemail. I leave a message: I have identified that the Interim Procurement Director also held the Regulatory Liaison role simultaneously during the relevant period. I ask them to call back before end of day.
I hang up and sit with the org chart for a moment.
Most of my cases take months to build. Months of building the evidentiary chain: manifest to intake workflow to organizational structure to decision authority to the person who exercised it. This one has taken eleven days from initial escalation to a named role with documented dual obligation.
I do not know yet if there is a name behind the role. The four blacked-out names might include it. Or they might not — acting titles can persist after the person has left, and if the person left before the Act's enforcement provisions took effect, the criminal threshold becomes harder to establish.
But eleven days is not months.
I write the cross-reference in the case file and close the folder.
A decision is not the same as negligence. I have been building a case for negligence. What the org chart shows is something that requires a different argument, and a different section of the Act, and possibly a different outcome for the person who made it.
I have learned to be careful with that sentence.
I write it anyway.