Supply Chain Compliance Assessment
Specification
Define and implement a process for conducting internal assessments to confirm conformance and effectiveness of standards, policies, procedures, and service level agreement activities at least annually.
Threat coverage
Architectural relevance
Lifecycle
Data storage, Resource provisioning, Team and expertise
Design, Training, Guardrails
Evaluation, Validation/Red Teaming, Re-evaluation
Orchestration, AI Services supply chain, AI applications
Operations, Maintenance, Continuous monitoring, Continuous improvement
Archiving, Data deletion, Model disposal
Ownership / SSRM
PI
Shared across the supply chain
Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.
Model
Owned by the Model Provider (MP)
The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.
Orchestrated
Shared Model Provider-Orchestrated Service Provider (Shared MP-OSP)
The MP and OSP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.
Application
Owned by the Application Provider (AP)
The Application Provider (AP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer. The AP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the AP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The AP is accountable for carrying out the due diligence on its upstream providers (e.g MPs, Orchestrated Services) to verify that they implement the control as it relates to the service/product develop and offered by the AP. These providers build and offer end-user applications that leverage generative AI models for specific tasks such as content creation, chatbots, code generation, and enterprise automation. These applications are often delivered as software-as-a-service (SaaS) solutions. These providers focus on user interfaces, application logic, domain-specific functionality, and overall user experience rather than underlying model development. Example: OpenAI (GPTs,Assistants), Zapier, CustomGPT, Microsoft Copilot (integrated into Office products), Jasper (AI-driven content generation), Notion AI (AI-enhanced productivity tools), Adobe Firefly (AI-generated media), and AI-powered customer service solutions like Amazon Rufus, as well as any organization that develops its AI-based application internally.
Implementation guidelines
Auditing guidelines
1. Verify whether the Cloud Service Provider has a recurring, structured audit process to evaluate governance across cloud infrastructure, data storage, compute services, virtualization, and AI workload support (e.g., container orchestration, GPU provisioning, serverless functions). 2. Review audit documentation for issues such as misconfigured access controls, data residency violations, service availability risks, or insecure APIs. Confirm that corrective actions are tracked, resolved promptly, and aligned with cloud security standards, regulatory requirements, and internal policies. 3. Determine whether audit results are shared with relevant teams—such as cloud operations, compliance, and security—and that a feedback mechanism is in place to continuously improve audit effectiveness and ensure responsible cloud service delivery.
Standards mappings
42001: A.2.3 Alignment with other organizational policies 42001: A.10.3 Suppliers 27001: A.5.22 Monitoring review and change management of supplier services 27002: 5.22 Monitoring review and change management of supplier services
Addendum
N/A
Article 9 (2) Article 17 Annex VII 5.3
Addendum
Define a formal internal audit program that includes: supplier and SLA performance reviews, security/privacy policy compliance, a documented process within the QMS or compliance framework, a review schedule (e.g., annually or per risk/event triggers), and confirmation that reviews are extended to all relevant actors, not just high-risk providers.
GV-6.1-005
Addendum
N/A
C4 PC-01 C4 Section 4 (4.4.2.1) C5 SSO-04 C5 COM-02 C5 COM-03
Addendum
N/A
AI-CAIQ questions (1)
Is there a process for conducting internal assessments at least annually to confirm the conformance and effectiveness of standards, policies, procedures, and SLA activities?