About · Ownership · Independence

Who operates auditll144 — and why it is deliberately separated from consulting.

Full ownership disclosure below. We believe independence is a feature that compliance officers, general counsel and CHROs deserve to verify, not a claim buried in a footer.

Ownership

auditll144 is a trade name operated by Lexara Advisory LLC, a Wyoming limited liability company formed on March 27, 2026. Lexara Advisory LLC is wholly owned by its founding member, Constantin Răzvan Gospodin Florea. The entity conducts two distinct business lines that are intentionally kept operationally separate:

01

Lexara Advisory

AI governance consulting. Gap assessments, EU AI Act documentation, AI risk frameworks, LL144 compliance navigation. Served at lexaraadvisory.com.

02

auditll144

Independent bias audits for AEDTs under NYC Local Law 144. Does not advise audit clients on compliance strategy — that would void the independence the rule requires.

Separation in practice

The line between consulting and auditing — and how we hold it

The DCWP Final Rules implementing NYC Local Law 144 define an independent auditor, in part, as a person or organization that has not been involved in using, developing or distributing the AEDT, does not have an employment relationship with the employer or vendor, and does not have a direct financial interest — or a material indirect financial interest — with those parties.

We take the "material indirect financial interest" clause seriously. A single firm that sells LL144 compliance consulting to a client and then audits that client's AEDT is, in our reading, exactly the conflict the rule tries to prevent. The audit fee is small next to the consulting relationship, and the audit outcome becomes materially harder to disentangle from the business interest in keeping the consulting client.

So the operational rule is binary: a company is either an audit client of auditll144, or a consulting client of Lexara Advisory. Never both, and never in sequence within a 12-month window. The conflict check is documented in writing at engagement.

Auditor profile

The person signing your audit

Constantin Răzvan Gospodin Florea is a Spanish-barred lawyer (Ilustre Colegio de Abogados de Santa Cruz de Tenerife, nº 5961) with legal training in two EU member states and approximately a decade of practice experience in EU regulatory law. He is an IAPP AIGP candidate, author of the Guilty Algorithm blog-as-book on AI regulation in criminal justice and immigration law, and founder of Lexara Advisory LLC.

Relevant for LL144 audit clients in particular: most AEDTs used for NYC hiring in 2026 are simultaneously exposed to the EU AI Act as high-risk systems under Annex III. An auditor who understands the EU regulatory logic — not just as a checklist but as a system — produces an audit deliverable that anticipates the parallel conformity work the same AEDT will need.

Spanish Bar · ICATF 5961 EU legal training · 2 jurisdictions EU AI Act specialist IAPP AIGP candidate

Contact

Audit inquiries and independence conflict-check questions: advisory@lexaraadvisory.com. Phone: +1 (646) 381-2032.

For AI governance consulting (not audit): lexaraadvisory.com.