The new anti-corruption directive shifts liability from "who committed the infraction" to "why didn't your organisation prevent it." Demonstrating that a compliance programme functioned requires proof it was operational before the act — not documentation assembled after. With sanctions reaching 5% of global turnover or 40 million euros, this article establishes why that distinction is architectural, not procedural.

Faced with Shadow Runs and systemic frontier model drift, standard downstream observability (SIEM/EDR) fails. The SOURCE 0 doctrine introduces Opposability-as-a-Service (OaaS): an ex-ante cryptographic baseline and judicial escrow designed to protect directors by shifting the burden of proof back to the regulator.

Facing the downstream governance failure of agentic AI (Google, Nvidia), the SOURCE 0 Doctrine validates the market for opposability. Discover how T-0 cryptographic sealing and ministerial escrow address strict director liability under NIS 2 and DORA frameworks.