---
title: "Build a risk register for a federal AI-system purchase"
url: "https://ailawframework.com/practice/government-procurement-and-tendering/prepare-a-procurement-risk-register-for-an-ai-system-purchase/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A50-B7-4-US"
practice_area: "Government Procurement & Tendering"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build a risk register for a federal AI-system purchase

> From the risks the lawyer names, record the risk, the document it comes from, and a blank column for the lawyer's response. Do not score a risk and do not add a risk the lawyer did not name.

Canonical page: https://ailawframework.com/practice/government-procurement-and-tendering/prepare-a-procurement-risk-register-for-an-ai-system-purchase/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Government Procurement & Tendering](https://ailawframework.com/practice/government-procurement-and-tendering.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | From the risks the lawyer names, record the risk, the document it comes from, and a blank column for the lawyer's response. Do not score a risk and do not add a risk the lawyer did not name. |
| What the lawyer must review | ABA Model Rule 1.1 requires competent representation. ABA Formal Opinion 512 (29 July 2024) leaves the lawyer responsible for the use of a generative tool, including what procurement information is entered. FAR 9.505 requires each contracting situation to be examined on its particular facts. Its two stated principles are preventing conflicting roles that might bias a contractor's judgment, and preventing unfair competitive advantage. The register is a working paper. The lawyer decides which risks are accepted. |
| Written for | United States |
| Applies to | [Prepare a procurement risk register for an AI system purchase](https://ailawframework.com/practice/government-procurement-and-tendering/prepare-a-procurement-risk-register-for-an-ai-system-purchase.md) |

## Checking plan

- What the AI does: From the risks the lawyer names, record the risk, the document it comes from, and a blank column for the lawyer's response. Do not score a risk and do not add a risk the lawyer did not name.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A blank response column is not a finding that the risk is accepted.
- Sections 9.505-1 through 9.505-4 were not opened and are not applied here.

## Sources

- [ABA Model Rule 1.1, Competence](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_1_competence/) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)
- [FAR 9.505, Organizational and consultant conflicts of interest, general rules](https://www.acquisition.gov/far/9.505) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*