Agency Transfer Audit

Operational Dependency Audit

(Agency Transfer Audit)

For organisations where AI is used in any form — internal development, subsidiary structure, external provider or off-the-shelf AI tools — and where it is necessary to determine: is real control over the system’s decisions being maintained?


What is operational dependency?

Operational dependency is the condition in which an organisation does not merely use an AI system, but has fundamentally lost the capacity to function without it. Not through a single decision. Through a series of small delegations, each of which seemed reasonable at the time.

Staff stop practising the judgement that was previously routine. Emergency procedures go untested. Documentation falls behind reality. Competence erodes through habitual inaction.

When a regulator demands explanations or the system fails — the organisation discovers that the capacity to operate without the system exists only on paper. Explaining the decision is impossible. Stopping the consequences is too late. Accountability has already arrived.


Preliminary Diagnostic — first step (free)

The first step is a free self-assessment instrument. Three questions, ten minutes. The result shows which of three dimensions of control is already weakening: operational continuity without the system, preservation of staff competencies, and actual practice of overriding system decisions.

Download the preliminary diagnostic (PDF)


What we typically find

In organisations that have already deployed AI, the same patterns recur:

Control exists formally The procedure for overriding the system’s decisions exists in the regulations. In practice, it has never been applied.
Competence is concentrated Understanding the system’s logic is possible for one or two staff members. When they leave — a real gap in oversight.
Emergency mode has not been tested Manual operating procedures have not been verified since launch. No one knows whether they work.
Single source of answers Explaining why the system reached a specific decision is only possible by contacting its developer or provider.
Cost of exit is unknown No one has calculated what it costs to abandon the system or transition to an alternative solution.
Regulatory position has not been reviewed Compliance with Law No. ZRU-1115 and regulator requirements has not been analysed since AI deployment.

Each of these is not a theoretical risk. It is a specific question that will be asked during an inspection or after an incident.


Two audit formats


Express Diagnostic of AI Control

For organisations that need a rapid initial picture — or where the preliminary diagnostic has identified yellow or red zones.

What is included:

  • Diagnostic across three dimensions: operational continuity without the system, preservation of staff competencies, and actual practice of overriding system decisions
  • Covers all deployment models: internal team, subsidiary structure, external provider, off-the-shelf AI tools
  • Written report with a risk zone map

Duration: 5–7 working days.

Deliverable: written report for management. Confidentiality: complete. Results are not published or shared with third parties.


Full Operational Dependency Audit

For organisations where the scale of deployment requires a thorough assessment from the outset — or where the express diagnostic has identified systemic problems.

What is included:

  • Interviews with key staff involved in AI-assisted processes
  • Analysis of regulations and actual control practices — both declared and real
  • Quantitative assessment of dependency depth across multiple dimensions
  • Final report with a map of critical zones and specific recommendations
  • Management briefing session

Duration: 3–5 weeks.

Deliverable: report and management briefing. Confidentiality: complete. 


Who this is for

  • Commercial banks using AI in lending, scoring, fraud detection and risk management
  • Fintech companies and payment organisations
  • Insurance organisations with AI in underwriting and claims assessment
  • State enterprises using AI in operational processes
  • Organisations with internal development teams or subsidiary IT structures
  • Organisations using off-the-shelf AI tools and platforms in working processes — even where this is not formally described as “AI deployment”

Next step

To request a diagnostic or discuss the format, write directly.

Start with the free preliminary diagnostic — ten minutes, a first picture, no obligations. If the result shows yellow or red zones, we will hold a 30-minute working meeting about your specific situation.

Request a meeting: ok@okhodjaev.com | +998 90 352 83 50

All engagements are conducted under a Non-Disclosure Agreement (NDA).

Return to the full overview of AI governance services

Write to us

Please fill out the application form and we will contact you as soon as possible.