AI Governance and Approval

Start Here If You Are New to AI Governance

The DEPUTY COMMANDANT FOR INFORMATION (DC I) is the SERVICE LEAD for Marine Corps data and AI per CMC Memorandum (21 May 2019). DC I is the CENTRALIZED AUTHORITY for governance and oversight of all GenAI capabilities within the Marine Corps per MARADMIN 018/26. The MARINE CORPS SERVICE DATA OFFICER (MC SDO), serving under DC I, is the principal advisor to the CMC and CHAIRS the working groups. The FUNCTIONAL DATA WORKING GROUP (FDWG) governs data matters. The ARTIFICIAL INTELLIGENCE WORKING GROUP (AIWG) governs AI matters. Per MARADMIN 018/26 paragraph 4.a, ANY command or organization seeking to develop, procure, or field a SEPARATE GENAI CAPABILITY must coordinate with and receive APPROVAL from DC I prior to initiation. This ensures all efforts are interoperable, secure, and not duplicative. Per MCO 5231.4 and MARADMIN 018/26.

This page walks you through AI governance and approval from your seat as a Marine. By the end you will know.

• DC I as service lead and centralized AI authority
• MC SDO as principal advisor and working group chair
• FDWG and AIWG governance bodies
• Approval requirements for new AI capabilities
• The coordination process
• Data Stewards across Deputy Commandants
• Common situations requiring DC I coordination
• Why centralized governance matters

Every fact on this page comes from MCO 5231.4, MARADMIN 018/26, the CMC Memorandum to DC I (21 May 2019), DEPSECDEF Memorandum (26 May 2021), DoD Responsible AI Strategy, and Executive Order 14110.

DC I as Service Lead

Per CMC Memorandum dated 21 May 2019, the Deputy Commandant for Information (DC I) is appointed as the Marine Corps service lead for data and AI.

DC I Responsibilities

• Represent the Marine Corps to DoD organizations on data and AI matters.
• Oversee MC SDO activities.
• Serve as Marine Corps Enterprise Operations Management, Intelligence, and Geospatial Data Steward.
• Serve as the Marine Corps Authorizing Official (AO) for IT systems.
• Implement compliance with VAULTIS standards.
• Implement compliance with Responsible AI principles.

Centralized AI Authority

Per MARADMIN 018/26 paragraph 4.a, DC I is the designated authority for governance and oversight of all GenAI capabilities within the Marine Corps.

MC SDO as Principal Advisor

The Marine Corps Service Data Officer (MC SDO) is the principal advisor to the Commandant of the Marine Corps for data and AI. The MC SDO.

• Establishes data and AI policy for the Marine Corps.
• Represents service-component authoritative data and AI matters at the MCBC, MCIEE Board, and MROC.
• Coordinates with services and secretariat-level organizations regarding the CMC position.
• Serves as final approval authority in the Marine Corps for data and AI.
• Publishes annual Data Implementation Plan and AI Implementation Plan.
• Be accountable for service compliance with ethical AI principles.
• Chairs the FDWG and AIWG.
• Appoints Associate Data Officers (ADOs).

Functional Data Working Group (FDWG)

The FDWG is the service-level body for DATA governance.

Composition

• Chair. MC SDO.
• Members identified in the charter.

Function

• Provides recommendations to the appropriate governing body.
• Provides alignment of policy and resourcing decisions that impact the Marine Corps Total Force.
• Reports to the MCBC.

Charter Cycle

The FDWG updates its charter every three years. As necessary, uses memorandums of understanding to drive delivery.

Artificial Intelligence Working Group (AIWG)

The AIWG is the service-level body for AI governance.

Composition

• Chair. MC SDO.
• Members identified in the charter.

Function

• Provides alignment of policy, resourcing decisions, and ethical and responsible AI principles that impact the Marine Corps Total Force.
• Provides recommendations to the appropriate governing body.
• Reports to the MCBC.

Charter Cycle

The AIWG updates its charter every three years.

Approval Requirements for New AI Capabilities

Per MARADMIN 018/26 paragraph 4.a. Any command or organization seeking to develop, procure, or field a separate GenAI capability MUST.

• COORDINATE with DC I.
• RECEIVE APPROVAL from DC I prior to initiation.

Why

• Ensure all efforts are interoperable.
• Ensure all efforts are secure.
• Ensure all efforts are not duplicative.

What Constitutes "A Separate GenAI Capability"

• Procuring a new commercial AI tool for command use.
• Developing an internal AI tool.
• Deploying an AI agent for command-specific tasks.
• Integrating AI into a command system or workflow.

What Does NOT Constitute "A Separate GenAI Capability"

• Using GenAI.mil or another platform in the enterprise ADS baseline. Per MARADMIN 325/26, the baseline covers War Data Platform (WDP), Maven Smart System (MSS), GenAI.mil, Low-Code Application Development Platform (LCAP), Local Development and Data Science Environment, and Tactical Assault Kit (TAK).
• Using CamoGPT or other previously authorized systems within their approved purpose.
• Personal use of commercial AI for non-Marine Corps purposes.

See Enterprise AI, Data, and Software Platforms for the baseline.

The Coordination Process

Step 1. Identify the AI Need

Command identifies a problem that AI could solve and a potential AI capability.

Step 2. Engage DC I Through Service Data Office

Contact DC I SDO for initial coordination. POC contacts include the AI Lead and USMC Service Data Officer.

• Major C. D. Clark, Artificial Intelligence Lead, DC I SDO. Phone 703-692-3780. Email CHRISTOPHER.D.CLARK.MIL@USMC.MIL.
• C. A. Crosby, HQE, USMC Service Data Officer, DC I SDO. Phone 703-693-9979. Email COLIN.CROSBY@USMC.MIL.

Step 3. Document the Capability

Provide DC I with documentation including.

• The problem being solved.
• The proposed AI capability.
• Data sources and data classification.
• Security posture.
• Interoperability with enterprise systems.
• Why GenAI.mil or existing approved tools cannot meet the need.

Step 4. AIWG Review

The AIWG may review and provide recommendations to DC I.

Step 5. DC I Decision

DC I approves, conditionally approves, or denies. Conditional approval may include requirements like security architecture review, interoperability standards, or coordination with COMMARCORSYSCOM.

Step 6. Implementation Under Approval

Command implements per the approval, with ongoing oversight.

Portfolio Management and FAM Coordination

Per MARADMIN 325/26. AI, data, and software (ADS) work carries a portfolio-management layer on top of the DC I approval path.

Consult the FAM Before You Develop

Before initiating an ADS capability, consult the USMC Artificial Intelligence Working Group (AIWG) and the applicable Functional Area Manager (FAM). The FAM owns the functional boundary the capability sits in. The ADS Information Resource Manual (IRM) lists FAMs, their boundaries, and points of contact.

Quarterly Portfolio Assessment

Capabilities developed on enterprise platforms undergo a quarterly portfolio-management compliance assessment. Applicable portfolio-management policies live in the IRM and MCO 5230.21.

Requirements Beyond the Enterprise Baseline

If the mission needs a capability the enterprise does not provide, coordinate with FAMs to determine the capability-development and approval process. See Enterprise AI, Data, and Software Platforms for the baseline and governance path.

Data Stewards Across Deputy Commandants

MCO 5231.4 designates Deputy Commandants as Data Stewards for specific domains. These stewards inform MC SDO data management and AI policy development.

• DC I. Enterprise Operations Management, Intelligence, and Geospatial.
• DC CD&I. Warfighting and Force Application (with MROC oversight).
• DC P&R. Financial.
• DC M&RA. Human Resources and Human Capital.
• DC AVN. Aviation.
• DC PP&O. Readiness.
• DC I&L. Logistics and Sustainment.
• COMMARCORSYSCOM. Acquisition.
• CG TECOM. Training and Education.
• Communication Directorate (CD). Visual Information.
• Office of Legislative Affairs. Legislative.
• CL and SJA. Legal.

Data Steward Responsibilities

• Identify, designate, and register Authoritative Data Sources (ADS) in the Marine Corps data catalog.
• Identify and appoint Data Custodians and CDAOs.
• Attend FDWG and AIWG.
• Inform data and AI talent management for the workforce.
• Provide input to POM and PPBEA processes.

Common Situations Requiring DC I Coordination

Procuring a Commercial AI Tool

Command wants to use a commercial AI tool that is not GenAI.mil or already authorized.

Coordination. Engage DC I before procurement. AI Lead at DC I SDO is the contact.

Developing an Internal AI Capability

Command develops an AI agent, classifier, or other capability for command-specific use.

Coordination. Engage DC I before development. Coordinate with MCSC for acquisition aspects.

Adopting AI in an Operational Process

Command integrates AI into an operational workflow, planning process, or intelligence task.

Coordination. Engage DC I and the relevant Data Steward (e.g., DC CD&I for warfighting).

Cross-Service AI Coordination

Command coordinates with other services or DoD agencies on AI matters.

Coordination. DC I serves as the Marine Corps representative to DoD AI organizations.

Legal or Ethical Concerns

AI use raises legal or ethical questions.

Coordination. Engage SJA and CL for legal review. Engage DC I for AI policy interpretation.

Why Centralized Governance Matters

Prevent Duplication

Multiple commands procuring or developing similar AI tools wastes resources. Centralized coordination ensures efficient use.

Ensure Security

AI tools handle sensitive data. Centralized review ensures security posture meets DoD standards.

Maintain Interoperability

AI tools should work with enterprise systems. Centralized coordination drives interoperability.

Apply Responsible AI Principles

DC I enforces compliance with Responsible AI principles across the service.

Comply With Federal Requirements

Per Executive Order 14110 and OMB Memorandum M-24-10, federal agency AI use requires governance and risk management. DC I coordinates this for the Marine Corps.

Common Errors

Procuring AI Without DC I Coordination

Command procures AI tool independently, creates security and interoperability problems.

Mitigation. Always coordinate with DC I before procurement.

Treating GenAI.mil as Insufficient Without Reason

Command pursues separate GenAI capability assuming GenAI.mil cannot meet the need, without first engaging DC I.

Mitigation. Engage DC I to evaluate whether GenAI.mil or existing approved tools suffice.

Ignoring Data Steward Coordination

Command develops AI capability without coordinating with the relevant Data Steward.

Mitigation. Identify which Data Steward owns the data domain. Coordinate.

Failing to Document AI Use Case

Command implements AI without documentation, creating audit and accountability issues.

Mitigation. Maintain documentation of AI use cases, data sources, and approvals.

Cross References

• For overall AI framework, see AI Overview and Authorities
• For GenAI.mil as the approved enterprise platform, see GenAI.mil Enterprise Platform
• For other approved tools requiring command-level authorization, see CamoGPT and Other Approved AI Tools
• For ethical principles, see AI Ethical Use
• For workforce roles, see Data and AI Workforce Roles
• For NPS Fellowship as one DC I SDO program, see AI Fellowship Programs (NPS)
• For the enterprise-platform baseline and portfolio governance, see Enterprise AI, Data, and Software Platforms

Quick Reference

• Authority. MCO 5231.4 and MARADMIN 018/26.
• Service lead. Deputy Commandant for Information (DC I).
• Principal advisor. Marine Corps Service Data Officer (MC SDO).
• Working groups. FDWG (data), AIWG (AI). Both chaired by MC SDO.
• Approval required for. Any new GenAI capability beyond GenAI.mil and previously authorized systems.
• POC. DC I SDO, AI Lead (Major Clark) or Service Data Officer (Crosby).
• Data Stewards. 12 designated by domain.

Records To Keep

• DC I approval correspondence for any AI capability
• Documentation of AI use case and data sources
• Records of FDWG or AIWG decisions affecting your command
• Data Steward coordination records

If you have a question about AI governance or seeking to develop or field a new AI capability, contact DC I SDO at the POCs above. For data domain questions, identify the relevant Data Steward and engage them in coordination with DC I.