Overall, it looks like a decently constructed pack using good materials, but I believe it’s a custom one-off or a heavily modified item based on these photos. There are some companies that may construct a prototype this way, but it’s not common. Too many inconsistencies to even speculate on a manufacturer.
I’m seeing some problems with this thing; and serious material inconsistencies. I can’t make out the year on those coyote brown national molding buckles, but that thick golden webbing was out of spec for field gear by the time those buckles came into production (I've never seen them used together, ever). Also, almost all decent manufacturers stopped shipping those rattletrap zipper pulls by the time the cb nat molding hardware hit production. It’s also unusual to see milspec gear with an odd number of pals columns after the early 2000’s (there are several major examples though). Rarely are pals rows all different lengths while on the same ladder either. The design has some “no nos” that most companies wouldn't do. Way too many little things that would prevent/indicate this was not mass produced. The hook pile on the pouches is all kinds of wrong. The triple D-ring thing is almost nonexistent for milspec gear. I can’t tell what type of bias/binding tape is on it; of it there are any plotting chalk lines. Is the thread different colors even? That second zipper over the dry bag zip is completely redundant and serves no purpose? Zipper brand?
I'd take pride in what is probably a one of a kind if I were you.