Prepared by ESL — AI-based SDLC consultants

Amp as an Evidence-Generation Pipeline

SPDF Control Mapping for FDA Premarket Cybersecurity Submissions — answering "who verifies the verifier" after Anthropic's Agentic Misalignment (Summer 2026) findings, grounded in algorithmic-auditing literature on auditor independence (FAccT '22; Kim et al. 2026).

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17
Pages
13
Controls A-01…A-13
9
Threats T-01…T-09
5
Verification Layers

Amp is used as an evidence-generation and orchestration layer for FDA SBOM/VEX and process-specific submissions — Static Code Analysis, Unit Testing, Code Coverage, and Penetration Testing — such that no single AI verdict is load-bearing and every compliance claim has deterministic, cross-vendor, and human sign-off.

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Page 2

Architecture Overview

The single-picture summary: work flows through five layers; verdict authority increases upward.

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Page 3

Purpose & Threat Model

Five Anthropic-derived threats plus process-specific cover-up vectors, framed against FDA/NIST expectations.

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Page 4

The Verification Stack

L0–L4: deterministic checks, cross-vendor oracle, named human judge, immutable evidence.

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Pages 5–11

Control Catalog (A-01…A-13)

Thirteen audit-ready controls, each with what it controls, implementation, evidence artifact, and auditor re-check.

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Page 11 · NEW

A-13 — Static-Analysis Suppression & Baseline Integrity

Centered on Parasoft C/C++test. Turns the suppression surface itself into evidence — rule-pack hash, scope, baseline delta, suppression diff, signed register.

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Page 12

Coverage Matrix

13 controls × 9 threats. Every threat has ≥2 controls; no threat relies on a single control.

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Pages 14–15

Process-Specific Extensions

How the 5 layers redistribute per process — including the Static-Analysis Evidence Shape (§9.4).

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Pages 16–17

Caveats & References

Honest caveats and the full reference list — FDA, IEC, NIST, Anthropic, FAccT '22, Kim et al. 2026, Parasoft.

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