Yes, it does
Your own policy requires validation the estate does not have
Your governance policy (as you described it) commits to independent validation of the models that reach a consumer. That is your own commitment, and the system you described does not meet it. A missing validation on its own is one finding. This is worse than that, because a reviewer who reads your policy and then looks at your estate learns that the policy describes a practice you do not follow. Once they have found one control that exists only on paper, they start checking the others the same way.