Privacy policies may contain internal contradictions in which commitments are undermined by practices documented elsewhere in the same policy. We operationalize this phenomenon, privacy washing, through a four-stage pipeline: statement extraction, compatibility filtering and natural language inference screening, multi-model judge verification, and thematic analysis, with contradictions confirmed by majority vote of a three-model LLM panel. Applied to two corpora of website privacy policies, 123 collected in 2026 (OPPT) and 115 collected in 2015 (OPP-115), the pipeline finds the same category patterns recurring across the 11-year gap, with third-party sharing contradictions the majority of confirmed cases in each primary run, consistent with structural factors in policy composition rather than necessarily intentional deception. At least one panel-confirmed contradiction appears in 12.2% of OPPT companies (15/123; 9.8% excluding legacy pairs) and 36.5% of OPP-115 companies (42/115). A stability re-run seven months later, with a fully separated configuration (new extraction models, judges from three Chinese providers absent from both corpora, matched filters, no judge-submission similarity threshold), reproduces the OPPT prevalence under the original protocol (13.0% vs. 12.2%), finds sub-threshold pairs confirm at rates of the same order as those above (raising prevalence to 20.3% and 40.9%), and shows the third-party majority is panel-sensitive while the recurrence of the same category pairs is not. Two caveats govern all figures: panel verdicts are not validated against human expert judgment, so precision is unknown and prevalence figures are lower bounds; and the two primary runs used different filter configurations, so their prevalence difference is not interpretable as a corpus or era effect (the matched re-run reduces the gap to roughly twofold but does not eliminate it).
Pharmaceutical sponsors developing a drug for both the United States and the European Union must reconcile guidance issued independently by the FDA and the EMA. Where the two agencies require substantively the same thing, a sponsor can file once; where they diverge, a single trial design risks rejection in one region; where one agency is silent on a point the other regulates, the sponsor must infer obligations. Today this reconciliation is performed manually by regulatory-affairs experts. We introduce cross-jurisdiction regulatory divergence detection: given an FDA requirement and an EMA requirement on the same topic, classify their relationship as AGREE, DIVERGE, or SILENT. SILENT is inherently directional (SILENT_FDA vs. SILENT_EMA); we record direction per pair and report per-direction F1 alongside the collapsed label. We release RegDivergence-101, a 101-pair expert-grounded pilot evaluation benchmark (labels grounded in three peer-reviewed FDA/EMA comparison studies and primary FDA/EMA/ICH guidance text; dual-annotation inter-annotator kappa = 0.85), and systematically characterise a four-method baseline hierarchy: lexical heuristic (0.511 macro-F1, 95% CI [0.411-0.605]), NLI cross-encoder (0.233), obligation-level Graph-RAG (0.663 [0.570-0.747]), and flat LLM judge / Claude Haiku (0.830 [0.747-0.908]). Three directional observations emerge at pilot scale (n = 101): SILENT is semantically detectable but invisible to entailment-only formulations; pair-level obligation graphs improve over lexical methods but trail flat-LLM context (CIs partially overlapping); and corpus-level graph construction is the indicated architectural target for large-scale silent-detection. RegDivergence-101 is a pilot release establishing the task formulation and baseline hierarchy; four unrepresented regulatory domains and an expansion roadmap are described in Section 7.