PROJECT PAUSED · Live API offline. Published samples remain verifiable. Inquiries stay open.
Signed fields an examiner can verify outside the producing systemSigned fields verifiable outside the system
signed.payout.recordverified
proof_idprf_fe22c21f8edaed3d
packfinance/payout_approval
decisionDENY
input_hash9f3733c79830bc0a
key_iddemo_bank_ec_1
algorithmECDSA-P256-SHA256
verify a real record

Published signed record (synthetic payout case): really signed, really verifiable; verification fails if a single byte changes. More signed examples in the appendix.

RECORDED
2026·06·10

When the model or vendor changes, can you still verify the record of this decision?

A denied applicant, a dismissed AML alert, a model-risk call. When the system that produced the decision has changed, the record has to stand on its own. Notary Cloud is an evidence-integrity layer that signs covered fields from the decision declaration and context your system submits. It preserves an externally verifiable record of what was declared, on which supplied inputs, and under which declared model and policy state, in a form that does not depend on the runtime that made the call. Regulation B requires adverse-action reasons to be specific and to accurately describe factors actually considered or scored. A signed record can bind the stated reason and supplied decision context for later comparison. It does not independently observe the model's computation or prove that the stated reason was actually used.

Verify a real record now. The sample page runs ECDSA P-256 verification in your browser against a public key served separately from the record, not held in the page. A second public record carries a daily batch root timestamped by an independent RFC 3161 authority. The token ships inside the record and verifies offline with openssl.

Notary Cloud does not decide, screen, approve, deny, or file SARs. It records decision declarations your systems submit after deciding.

ECDSA P-256 sampleServer-assigned sequenceRFC 3161 batch anchoringUS + EU + CanadaLive in-browser verify
CHOOSE YOUR ENTRY

Three routes onto the record.

Same evidence layer underneath. Pick the path that matches how you would start. Each one ends in a signed, independently verifiable decision record.

ON THE PUBLIC RECORD

Where this argument is already dated.

Filed comments are not regulator endorsement. They are dated evidence of the category argument, anchored to rulemaking the whole market is tracking.

TODAY · 2026-06-04
2026-04-17
Federal Reserve SR 26-2 issued
On record
2026-06-09
FinCEN NPRM comments close
Upcoming · 5 days
2027-05-01
OSFI E-23 effective
Upcoming

Regulatory comments

Three public comments filed in the FinCEN AML/CFT and PPSI rulemaking dockets.

FINCEN-2026-0034FINCEN-2026-0100

Signed sample

notary-cloud.com/r/prf_fe22c21f8edaed3dVerified

ECDSA P-256 proof generated through the local enforce lifecycle, verified in-browser against a separately served public key.

Architecture

SIGNED PROOF · proof_id + signature
DAILY BATCH · Merkle inclusion
TSA TOKEN · external stamp

Signing key held outside the producing runtime, public key retained separately; the record stays verifiable even if the runtime is gone. Deployer-held key custody is the pilot target mode; the public demo shows a deployer-labelled record verifying against a key served from a separate origin. The deployer can also declare the model and policy version inside the decision input. That declaration contributes to input_hash, which is covered by the signature; when the original input is available, later substitution changes the hash. Notary Cloud records the declaration — it does not verify it. The public demo records show two separate properties: declared versions displayed beside a signed input_hash, and a daily batch root timestamped by an independent RFC 3161 authority. The public artifact does not expose the input needed to recompute the version binding.

ECDSA P-256RFC 3161 anchoredDB-enforced controlsCustomer-held WORMVersion-binding
FOUNDER + STATUS

Credibility comes from restraint.

Notary Cloud is early and currently paused. The public record and in-browser verifier remain available.

  • Built by Sviatoslav Zhuravlev, the person who filed the FinCEN AML/CFT and PPSI rulemaking comments.
  • Project on hold. The live API and write demo are offline; published sample records remain verifiable.
  • Pre-revenue. No paying customers and no completed pilots yet.
  • If Notary Cloud stops operating, an exported record and the retained public key can still be verified without re-running the runtime. Deployer-held key custody is the pilot target mode; today the pilot key is held by Notary Cloud, and the deployer-labelled demo record shows external-origin key verification.
  • The pre-revenue status is labelled plainly because this is evidence you may have to defend to your own examiner.
  • The implementation and published examples are described below; live service is paused.
DIRECT PILOT

A concrete next step for a CCO or BSA officer.

Start with one decision class where the institution already carries examination risk: an automated adverse action such as a denial, an AML alert disposition, or a model-risk-relevant compliance call.

01

Scope

One consequential decision stream, one evidence schema, one verifier path.

ONE STREAM
02

Walk-away

A set of signed sample records, review notes, and a go/no-go production outline.

GO / NO-GO
03

Terms

90-day pilot shape. No annual lock-in. OEM pricing remains on the partner pricing page.

90-DAY SHAPE
ONE RECORD, THREE REGIMES

One verifiable AI decision record across US, EU, and Canada.

The legal tests differ. The evidence object is similar: a signed decision declaration whose covered fields can be checked later and compared with independently obtained evidence about model, policy, and execution. The record does not establish those source facts or population completeness by itself.

US

Adverse-action + AML evidence

For adverse actions, Regulation B requires specific principal reasons that accurately describe factors actually considered or scored. A signed decision record can preserve the reason and supplied decision context for later comparison, but it does not independently observe the model computation. The same record can preserve what an AI-enabled AML/CFT process declared when program effectiveness is questioned.

ECOA / Reg B12 CFR 1002.9
EU

EU AI Act Article 12 + 26

The same record shape supports lifecycle logging evidence and deployer reconciliation when a high-risk system's output must be reconstructed later.

AI Act Art. 12Art. 26
CA

OSFI E-23 + FINTRAC posture

Canadian model-risk and PCMLTFA / FINTRAC recordkeeping pressure points ask the same examination-time question: can the institution produce the record?

OSFI E-23PCMLTFA
HOW IT WORKS

Four moves from decision to externally verifiable record.

01

Upstream system decides

Your agent or model makes a decision inside your stack. Dismiss, escalate, hold - that call stays yours.

aml.screener -> sar_dismissed
02

Notary Cloud records

You send the decision with its rationale and inputs. We canonicalize the payload and write a signed audit record.

decision payload -> signed record
03

Record is signed

The record is signed by the configured signing key. This public sample uses ECDSA P-256.

signature + key_id
04

Batch root is anchored

Daily record batches are hashed into a Merkle root and timestamped through an RFC 3161 TSA endpoint. The public demo record carries the timestamp token and Merkle inclusion data needed for offline verification. The job must run; anchoring is not magic.

daily_root + tsa_url
FIELD → CONTROL

What each field in the record is for.

A proof bundle is useful only when each field's trust boundary is explicit. Some values are signed; registration metadata and external anchors support separate claims. Each mapping below is evidentiary context, not a compliance badge.

proof_and_registration = {
model_version, policy_version: "v4.2 / p18",
Model-risk reconstruction

Version declarations committed through input_hash. The public demo displays the declarations beside that hash but does not expose the input needed to recompute the binding. The declarations are recorded, not verified.

SR 11-7 / SR 26-2OSFI E-23
input_hash: "7d35c7ba…9417",
Submitted-input integrity

A commitment to the submitted input. It detects later change when that input is available; it does not prove what the model actually considered or scored.

ECOA / Reg B12 CFR 1002.9
timestamp: "2026-05-18T13:28:36Z",
Declared record time

The time asserted inside the signed proof. It is not independent time. A verified Merkle inclusion path plus RFC 3161 token shows that the record was in the batch by the token's genTime; it does not establish decision or application-registration time.

EU AI Act Art. 12
signature: "MEUCIHvV…" // ECDSA P-256
Signed-field integrity

A valid signature shows that the signed fields have not changed. Attribution depends on who controls the key and how that key was registered.

NIST 800-53 AU-10
seq_no: 418823 // registration metadata
Post-admission anomaly signal

A server-assigned order after admission. Gaps can trigger investigation; seq_no is not part of the signed proof and does not show that every source event was submitted.

}

These are evidentiary mappings, not compliance certifications. No field by itself proves source completeness, semantic truth, or actual execution.

INSTITUTIONAL CHANGE

The system on file is rarely the system that produced the record.

Per-decision evidence is not enough if the institution cannot later show which system, model, policy, vendor, and custody state existed when the decision was made.

Examination question

You switched vendors last year. Can you still produce the evidence for a decision the old vendor's system made?

Preservation duties and lifecycle logging duties can collide with data-minimization and erasure duties. Lifecycle logging says little about who controls the logs after the system changes hands.

01

Adoption is a representation.

A procurement memo, model inventory entry, or vendor statement says what was adopted. It does not guarantee the evidence environment will still exist when the decision is examined.

02

The system changes.

Models retrain, policies revise, retention changes, vendors switch, and custody moves. The system on file is rarely the system that produced the record.

03

The evidence splits.

When the model, the policy, or the vendor changes, the evidence does not move cleanly with it. It splits across parties, systems, and retention duties.

Notary Cloud's public posture is narrower: receive a decision declaration outside the producing runtime, sign the covered fields with a configured key, and keep the resulting proof independently checkable. Key attribution, source truth, and population completeness remain separate. This section states the institutional evidence gap, not a solution design.

FAILURE SCENARIO

The cost appears when the examiner asks for the record.

A sober version of the downside: not a breach, not a headline, just an institution unable to prove the state of a consequential AI decision.

The institution produces a vendor export from the current system. The decision was made by the old system.

vendor_export.csvcurrent system
MISMATCH
decision_record · v1_modelold system · gone

The reviewer can see a row, but cannot independently test whether the row is complete, whether the policy state matches the date, or whether the export changed after the vendor migration. Mutable logs can still be useful. They are weaker evidence when the institution carries the burden of reconstruction.

ROUTES

Find the right surface fast.

Different buyers need different proof. The site routes to existing detail instead of duplicating it.

PILOT REQUEST

Leave a note about one decision class.

The project is on hold. Share an inquiry or use case here; replies may take time. Email remains available for attachments.

Email instead

Form submissions are emailed to the project inbox. Do not include secrets or customer data. Read the pilot protocol.

EXAMINATION TIME

Admissibility is a later decision.

The record matters when a reviewer asks whether the evidence survived the system, vendor, policy, and custody state that produced it.

01

Examination-time evidence

Runtime authority decides whether an action can bind consequence now. Notary Cloud preserves the submitted declaration so a later reviewer can test the covered fields without asking that runtime to recreate them. Source truth and coverage remain separate questions.

02

Company-disappearance risk

If the deployer retains the signed record, a trustworthy public-key reference, and any anchor material, past verification does not require Notary Cloud to re-run the decision system. When WORM replication is configured, the record also sits in the institution's own write-once storage under its retention lock.

03

Complementary slot

The record is not a SIEM, model monitor, case manager, or approval engine. It is the witness layer for consequential decision events.

Witness-layer position
PUBLIC VERIFY

A published or allowlisted signed record can have a verifier URL.

Share an authorized record with an examiner, a counterparty, or your CCO. The page verifies the signature client-side and shows the proof fields, canonical string, and public-key URL. It does not prove semantic truth, source completeness, or actual execution.

  • Signed proof ID in the URL
  • Signature validated in the reader's browser
  • Canonical string visible
  • Payload PII excluded through allowlist
View sample record
Signed record
DECISION RECORD
prf_fe22c21f8edaed3d
Signed
Pack
finance 1.1.0
Intent
payout_approval
Decision
DENY
Key
demo_bank_ec_1
Recorded
2026-06-10T21:54:27.248Z
Algorithm
ECDSA-P256-SHA256
SIGNATURE
MEUCIHvV2y5m+pWq9EiEepN7/AXdy/XooKUXBrReRdJZH3ZlAiEAzaEacCSXgOr22KZyF8QipS/SgGgOQlZ6QirRktc3hHg=
CHAINS

One chain per decision stream.

Each stream of consequential AI decisions gets its own chain. The engine is universal - chains define the shape of a valid record and the events that belong in that stream.

AML Screening
v1.0.0
active

Records SAR-relevant decisions - dismissed, escalated, filed - with the rationale and inputs a BSA examiner would expect.

sar_dismissed, sar_escalated, sar_filedLeave a note
Sanctions
v0.3.0
planned

Records OFAC list-match reviews and the rationale for each dismissal or freeze.

ofac_match_reviewednotify me
Transaction Monitoring
v0.2.0
planned

Records threshold-triggered alerts and how they were resolved across the case lifecycle.

alert_resolved, alert_escalatednotify me
HOW IT HOLDS UP

Built for the question an examiner asks in month six.

Each row describes the implemented code or published record. The live service is paused.

See signed proof
  1. 01
    CRYPTOWHEN CONFIGURED
    Configurable signing

    Records are signed by the configured proof key. ECDSA P-256 is implemented when key directories are configured; HMAC remains the default dev and legacy path. Attribution is only as strong as key custody and registration.

    Maps to: signed-field integrity and key-based attribution; NIST 800-53 AU-10 context

  2. 02
    INTEGRITYIMPLEMENTED
    Database-enforced record controls

    Records receive server-assigned sequence numbers. Database triggers block UPDATE and DELETE on protected record tables, while Postgres RLS separates tenant access. Privileged out-of-band storage access remains a trust boundary, and sequence gaps do not prove source completeness.

    Maps to: post-admission alteration and sequence signals

  3. 03
    STORAGEWHEN CONFIGURED
    Customer-held WORM retention

    When the customer's Object-Lock bucket is configured, signed records replicate into it (write-once retention), so the bytes sit under the institution's retention control, not ours. Deleting or rewriting a record inside the retention window is blocked by the customer's storage layer itself.

    Maps to: record retention; record-alteration detection (storage layer)

  4. 04
    TIMESTAMPPUBLISHED RECORD
    Merkle + RFC 3161

    A July 2026 record shows a Merkle inclusion path and timestamp token from an independent RFC 3161 authority. The token establishes that the root existed by its genTime. It does not establish the earlier application or decision timestamp. The live anchoring job is paused.

    Maps to: independent latest-existence bound

  5. 05
    AVAILABILITYIMPLEMENTED
    Fail-closed validation

    Records with unknown chains, missing required fields, or malformed rationale are rejected before storage. The upstream decision remains yours.

    Maps to: invalid action rejection

  6. 06
    PRIVACYIMPLEMENTED
    AES-256-GCM encryption at rest

    Stored enforce payloads and evidence blobs are encrypted with AES-256-GCM before storage.

    Maps to: payload confidentiality

  7. 07
    ISOLATIONIMPLEMENTED
    Tenant isolation

    Row-level security and FORCE RLS separate tenant records from runtime roles.

    Maps to: tenant boundary

  8. 08
    PRIVACYPARTLY IMPLEMENTED
    Payload minimization

    The public sample exposes only fields needed for verification. Customer schemas still need explicit allowlists before any real customer record is public.

    Maps to: data minimization

  9. 09
    OWNERSHIPRECORD DESIGN
    Deployer-controlled record

    The record sits in the deployer's evidence layer, not the vendor's runtime. Exportable, reconcilable, contract-independent of vendor terms.

    Maps to: vendor runtime boundary

  10. 10
    OPERATIONSPLANNED
    Transparency surfaces

    Public status, incident history, and key rotation log are not live today. They should ship before any production pilot claim.

    Maps to: security transparency

BUILD VS BUY

Why not just log it yourself?

This objection is valid. The gap is structural, not about whether your team can write logs.

01

A signature still authenticates an attestation.

If the institution holds the key, a valid signature attributes the declaration to that institution and makes later changes to covered fields detectable within the key-custody model. It does not make the declaration independent or true.

02

Separate custody narrows one failure mode.

Keeping a signed record and optional write-once copy outside the producing runtime can reduce the chance that one system change removes every copy. Privileged access and source events that were never submitted remain outside that claim.

03

Third-party verification has a limited object.

A reviewer can verify the signature over covered fields and, when present, the record's Merkle inclusion and the root's RFC 3161 time bound. Key identity, source facts, coverage, custody, and actual execution still require separate evidence.

04

Past verification and future issuance are different.

A past proof can remain verifiable when the record, trusted public-key reference, and any anchor material are retained. Institution-held key custody preserves the institution's ability to issue future records after a vendor exit, but those records remain institutional attestations.

Teams can build these controls themselves. Notary Cloud packages the narrower signing, registration, anchoring, and custody properties. Whether that is preferable to an in-house implementation is a pilot and procurement question, not a cryptographic fact.

QUESTIONS

Answers to what compliance teams actually ask.

Regulation B requires adverse-action reasons to be specific and to accurately describe factors actually considered or scored. Notary Cloud does not write your notice and does not judge whether the decision was fair. It preserves the stated reason and supplied decision context in a signed record so a reviewer can later test whether those fields changed and compare them with the source system. It does not independently observe the model computation, prove that the reason was actually used, or prove that every decision was recorded. Open a verifiable appendix example.

No. You already have screeners, case managers, and monitoring systems. Notary Cloud records the decision declaration and scoped context those systems submit. It preserves covered fields for later verification and comparison; it does not establish source truth, execution, or population completeness. We are the evidence layer underneath your existing stack, not a replacement for it.

The April 2026 NPRM credits institutions whose AI tools help demonstrate AML/CFT program effectiveness. Adoption alone gets no credit. Verifiable evidence of effectiveness is the kind of demonstration an effectiveness-based approach calls for.

Signing is synchronous. Anchoring is asynchronous and should not block the upstream decision. I will publish latency numbers only with a dated benchmark artifact, because made-up p50/p99 claims are worse than no numbers.

Your decision still happens. What is at risk is the record. A pilot design should decide whether to queue records locally and replay them later, or fail-closed on recording for high-risk decisions. That is a customer risk decision, not ours to hide.

Not today. Customer co-signing and BYOK are roadmap items. HSM/KMS-backed signing is not live in the current product.

Most of this site speaks to compliance officers at US banks and fintechs. If you build AI compliance agents that those institutions buy, the partner pages explain how Notary Cloud sits under your product as an evidence layer. Direct, co-brand, and white-label options are scoped during the pilot.

Runtime logs can support reconstruction, but they leave internal audit dependent on the system and operator under review. Notary Cloud adds a separately signed record that can be verified and compared with the platform's own evidence. It does not make the record complete or true by itself.

Different layer, different time scale. Runtime enforcement platforms decide whether an AI-initiated action may proceed. Notary Cloud decides nothing at runtime; it preserves a submitted decision declaration for later integrity checks. The layers can complement each other, but a Notary Cloud record does not prove that an action executed or that every action was recorded.

It is still an attestation by the key holder. A valid signature authenticates the signing key and makes later changes to signed fields detectable; it does not prove that the declaration was true. Additional assurance can come from an independent RFC 3161 timestamp over the batch, separately controlled retention, and reconciliation against another source. The public demo proves cryptographic verification and anchored inclusion, not source completeness or actual execution.

Your core makes decisions. Your SIEM collects logs. Notary Cloud records a separately signed decision declaration that a later reviewer can verify and compare with those systems. Changes to signed fields break verification. This does not establish source completeness or actual execution, and it does not replace either system.

The structural problem is the same. Canadian federally regulated financial institutions operate under OSFI E-23 for model risk management and under PCMLTFA recordkeeping requirements that FINTRAC can request on examination. A signed record can preserve what an AI system declared it decided, the supplied inputs, and the declared model version for later examination. It does not prove source truth, actual execution, or completeness. Configurable signing, database record controls, and RFC 3161 batch anchoring do not depend on which regulator is asking.

OSFI E-23 expects financial institutions to maintain model-lifecycle documentation and evidence. Notary Cloud can preserve a declared model version, policy state, input hash, decision label, and timestamp in a signed event for later comparison. It does not independently reconstruct what the model did, verify that the declarations were true, or prove that every decision was recorded. Whether the record is sufficient remains a matter-specific judgment for the institution and reviewer.