ADVERSARIAL VETTING PROTOCOL
NSPM-33 Compliant
INNOVATE Act 2025

Don’t Let a Silent Rejection
Kill Your Research Contract.

Identify disqualifying findings before the Government does — not after

Most engagements deliver within our 14 business-day target window.

The Problem

The Silent Rejection: No letter. No explanation. Just silence.

You’ve spent years building breakthrough technology. You’ve won your Phase II SBIR. Production is within reach. Then silence. Just a contract that never materializes.

This happens when hidden Foreign Ownership, Control, or Influence (FOCI) surfaces during the DoD’s vetting. A key researcher's past undisclosed affiliation with the Thousand Talents Plan or Changjiang Scholars Program. An investor three layers deep with ties to a sanctioned entity.

Under the INNOVATE Act, true "transition readiness" is no longer just about Technology Readiness Levels (TRL). The statutory definition now demands an entity be demonstrably free of malign foreign talent recruitment programs and complex FOCI vulnerabilities before production funds can be legally obligated.

By the time you find out, it’s too late. The DoD doesn’t tell you what they found. They just move on.

ITAR/EAR Compliant
Immutable Audit Trail
Human Review on All Moderate-Confidence Findings
NSPM-33 / INNOVATE Act Rubric
14-Day Target SLA*
7-Day Data Purge

Adversarial Vetting. Not a Checkbox.

Our protocol systematically interrogates every layer of your personnel and ownership structure using the same databases the government uses.

*Timeline targets shown. SLA clock pauses during documented third-party service outages.

Sayari Graph
OpenSanctions
OFAC SDN
Dimensions
WIPO PatentScope
Sayari Graph
OpenSanctions
OFAC SDN
Dimensions
WIPO PatentScope
Sayari Graph
OpenSanctions
OFAC SDN
Dimensions
WIPO PatentScope
Phase 1 (Days 1–5)

Parallel Discovery

Three specialized AI agents work simultaneously to build an independent picture of your risk exposure.

The Inquisitor

Scans personnel against research databases and co-authorship networks. Checks SciENcv disclosures against reality.

The Genealogist

Traces ownership layer by layer, identifying shell entities and beneficial owners. Doesn't stop at layer one.

The Auditor

Builds an independent evidentiary baseline from WIPO patent filings and a secondary parse of your SciENcv — before it receives findings from other agents.

Phase 2 (Days 6–9)

Cross-Validation

The Auditor becomes the triangulation engine, cross-referencing personnel and ownership risks to surface six categories of COI. The Sentinel validates findings against global sanctions.

Human analysts review all moderate-confidence findings.

Phase 3 (Days 10–14)

Vetting Pack Delivery

The Architect compiles validated findings to produce the Transition Readiness Score (TRS) (0–100 scored dashboard), trigger Adverse Finding Briefings if critical risks surface, and build the Merkle-chained audit log. Senior analyst sign-off before delivery.

Phase timelines are targets based on typical engagement complexity. The protocol depends on third-party federal databases.

Your final deliverable proves defensible diligence for DoD transitions.

Automatic Escalation: Adverse Finding Briefing

If disqualifying findings are detected during discovery or cross-validation, the protocol automatically halts and triggers an immediate Adverse Finding Briefing. We don’t wait until Day 14 to deliver critical news—you receive actionable intelligence the moment it is verified by an analyst.

The Protocol Architecture

Five Agents. Five Domains. One Adversarial Protocol.

Each agent operates independently within its own data silo. No single agent sees the full picture. That’s by design — the same compartmentalization principle the government uses, built into the architecture of the protocol itself.

Phase 1

The Inquisitor

Personnel Vetting

Finds what your researchers didn’t disclose. Resolves key personnel to their canonical research identity.

Co-authorship patterns with DoD 1286 institutions
Pattern omissions in SciENcv
Tools: Dimensions, ORCID, SciENcv Parser
Phase 1

The Genealogist

FOCI & Corporate Governance

Traces who really owns your company — past the cap table your lawyer gave you.

Shell entities in secrecy jurisdictions
Nominee look-through protocol
Tools: Sayari Graph, Middesk, Kharon
Phase 1 & 2

The Auditor

Discrepancy Analysis

The only agent that works both shifts. Catches what falls between the cracks of personnel and ownership.

Independent WIPO patent baseline
Cross-references Personnel vs. Ownership
Produces: The Gap Analysis Report
Phase 2

The Sentinel

Sanctions Validation

The last checkpoint. Multi-list amplification surfaces risks that single-database checks miss.

Tools: OFAC SDN, FinCEN, Visual Compliance
All Phases

The Architect

Orchestration & Compilation

The agent that never investigates — but controls everything. It routes data between agents, manages the phase gate state machine, and compiles the final Vetting Pack. It creates the Merkle-chained audit log that proves your diligence.

Manages inter-agent routing (no direct comms)
Triggers Adverse Finding Protocols
Produces: Transition Readiness Score
Produces: Mitigation Memos & Audit Log

What Each Agent Can and Cannot See

Agent Can See (Tier 1) Cannot See
The Inquisitor Raw publication data, co-authorship networks, SciENcv Cap-tables, ownership, sanctions results
The Genealogist Cap-table data, beneficial ownership, financials Publication data, researcher PII, patents
The Auditor SciENcv (secondary parse), WIPO patent records Raw cap-tables, raw publication data
The Architect Tier 2 Metadata & Signals only All Tier 1 Raw Data (Blind by design)

A Complete Security Posture Assessment.

Not a slide deck. Your Vetting Pack is the deliverable the DoD wishes every contractor brought to the table.

View Pricing

Transition Readiness Score

Produced by The Architect

Dashboard presenting overall security posture across Personnel Risk, FOCI Exposure, Sanctions, and Disclosure Integrity.

Gap Analysis Report

Produced by The Auditor

Organized into Missing Content (COI 1-3), Strategic Blindspots (COI 4 & 6), and Data Deficiencies. It surfaces conflicts at the intersection of people, entities, and disclosures.

Mitigation Memos

Produced by The Architect

Ready-to-file Proxy Agreements and Firewall Protocols, pre-populated with your specific findings from all agents. Not templates.

Tamper-Evident Log

Produced by The Architect

Timestamped, hash-chained record of every data query and analytical decision across all phases. Your defensible answer to investigators.

One Engagement. One Price.

No hourly billing. No scope creep. Know exactly what you’re investing.

Most Common

Standard Engagement

$15,000 Flat Investment

For organizations targeting a specific production contract or DD-254 submission.

  • Up to 5 key personnel
  • Up to 3 corporate ownership layers
  • 14 business-day target SLA (not a guaranteed delivery date — see Service Level & Dependencies)
  • Full Vetting Pack delivery
  • ITAR/EAR-compliant infrastructure
START ENGAGEMENT

Complex / Extended

Custom Scoped Separately

For multinational holding structures or organizations with complex personnel footprints.

  • > 5 key personnel
  • Deep ownership (> 3 layers)
  • Multinational holding structures
  • Specialized ITAR routing
CONTACT FOR SCOPING
The 14 business-day timeline is a target, not a guarantee. The FIDDA Shield protocol depends on third-party federal databases and commercial APIs that TensorLock does not own, operate, or control. Service disruptions, rate limits, or access changes by third-party providers may affect engagement timelines. TensorLock will notify you of any SLA-affecting events within 2 hours of detection.

Protocol FAQ

What does The Auditor do that the other agents don’t?
The Auditor is the only agent that operates in both Phase 1 and Phase 2. In Phase 1, it builds an independent baseline from patent filings and your SciENcv disclosures — before it knows what any other agent has found. In Phase 2, it receives anonymized findings from The Inquisitor and The Genealogist and cross-references all three sources to detect conflicts of interest, specifically personnel–entity conflicts.
Can one agent see another agent’s data?
No. Each agent has exclusive access to its own raw data, enforced architecturally. The Inquisitor cannot see cap-table data. The Genealogist cannot see publication records. All data flows route through The Architect, which itself is prohibited from accessing any agent’s raw data.
What happens when two agents disagree?
The protocol has a built-in reversal mechanism. If a downstream agent’s analysis contradicts an upstream finding, the contradiction is escalated to The Architect, which initiates a targeted re-query. The finding is never silently resolved — the discrepancy and its resolution appear in your Vetting Pack.
Why five agents instead of one?
A single system creates a single point of failure and bias. Five independent agents with compartmentalized access means that when findings from multiple agents converge, it is the strongest possible signal. The architecture is adversarial by design: each agent challenges the others through independent analysis.
Where exactly do humans get involved, and what decisions do they make?

Every engagement includes three mandatory human review checkpoints — no exceptions, no automated overrides.

  • Checkpoint 1 (Intake): Before any agent begins work, a human analyst reviews your engagement package — confirming entity identification, ITAR/EAR classification, personnel roster completeness, and SciENcv file integrity. If something is wrong at this stage, the engagement halts until it's corrected. This prevents a misidentified entity from cascading through all five agents.
  • Checkpoint 2 (Flag Review): After Phase 1 discovery completes, all findings in the moderate-confidence range (0.60–0.74) are queued for human review. These are findings where the data is suggestive but not definitive — exactly the kind of call that requires human judgment, not an algorithm. The analyst reviews the evidence and issues a verdict: approved, rejected with a stated reason, or modified with specific changes. Findings above 0.75 propagate automatically because the evidence is strong enough to stand on its own. Findings below 0.60 require corroboration from a second agent or data source before they go anywhere.
  • Checkpoint 3 (Vetting Pack Sign-Off): A senior analyst reviews and signs off on the final Vetting Pack before it reaches you. They check for false positive artifacts, verify that the narrative is coherent across all agent findings, and confirm that every mitigation memo recommendation is actionable — not generic boilerplate. No Vetting Pack is delivered without this sign-off.

Additionally, any time two agents produce conflicting results — for example, The Auditor and The Inquisitor parsing the same SciENcv field differently — the discrepancy is routed to a human analyst for resolution, not silently resolved by the system.

Who is responsible if the Vetting Pack misses something — TensorLock or the AI?

TensorLock. The AI agents are tools that execute the protocol. They do not bear responsibility. TensorLock designs the protocol, selects the data sources, defines the analytical logic, employs the human analysts who review findings, and delivers the Vetting Pack under our name.

That said, the Vetting Pack is a risk assessment based on the data available through authorized third-party sources at the time of the engagement — it is not a guarantee of clearance and not a legal opinion. If a data source was unavailable during your engagement, that gap is explicitly documented in the Gap Analysis Report so you know where your coverage ends.

If a finding was below the confidence threshold and didn't propagate to the Vetting Pack, that decision is recorded in the audit trail with the specific score and the threshold that excluded it. TensorLock takes responsibility for executing the protocol with commercially reasonable diligence, maintaining the integrity of the human review checkpoints, and delivering findings transparently — including findings we couldn't make because a data source was inaccessible.

What we do not take responsibility for is the accuracy or completeness of data maintained by third-party federal databases and commercial API providers that TensorLock does not own or control, or decisions made by the DoD or DCSA independently of the Vetting Pack.

Why We Built This

We watched deep-tech companies with genuinely transformative technology get stopped cold at the Production transition—not because their tech wasn’t ready, but because their security posture wasn’t.

The tools available to founders were manual, fragmented, and reactive. Cap-table reviews that missed the third layer. Compliance consultants who checked boxes but didn’t interrogate the data.

We built FIDDA Shield to close that gap. We created an adversarial vetting system that runs the investigation the DoD will run—before they run it—so founders have time to understand, mitigate, and document their posture.

Data Hygiene by Design

Raw data is purged within 7 business days of engagement acceptance. We don’t accumulate your sensitive information.

Compartmentalization

No single agent or person sees everything. Our protocol uses a tiered data compartmentalization model.

Dual-Phase Triangulation

The Auditor works blindly in Phase 1, then cross-references in Phase 2. Conflicts at the intersection of personnel and ownership are surfaced by architecture, not luck.

Let’s Find Out Where You Stand.

Schedule a scoping conversation within 48 hours.