---
name: compliance-gap-analyzer
description: "Maps current compliance policies against a specified regulatory framework (BSA/AML, NYDFS Part 500, UDAAP, GLBA, and similar), identifies every gap, and produces a prioritized remediation list with severity ratings, regulatory citations, and owner assignments. Use when assessing readiness for a new regulation, preparing for an exam or audit, validating an existing compliance program, or building a remediation roadmap after a regulatory change."
argument-hint: "[framework] [current-policy-state]"
allowed-tools: ["Read"]
---

# Compliance Gap Analyzer

## Purpose
Produce a clause-by-clause gap analysis between an organization's current compliance posture and a named regulatory framework — surfacing every missing, partial, or unevidenced control, rating each gap by regulatory and operational risk, and converting findings into a prioritized remediation plan an examiner would recognize as defensible.

## When to Use
Invoke this skill when the user asks to:
- Assess whether current policies meet a specific regulation (e.g., NYDFS Part 500, BSA/AML)
- Prepare for an upcoming regulatory exam, audit, or independent review
- Identify what's missing after a new rule or amendment takes effect
- Validate or stress-test an existing compliance program before attestation
- Build a remediation roadmap with priorities and owners
- Translate a regulatory framework into a control checklist mapped against current state

## Inputs Required
Before starting, collect:
- **Target framework**: The regulation or standard to measure against (e.g., BSA/AML, NYDFS 23 NYCRR Part 500, UDAAP, GLBA Safeguards Rule, Reg E)
- **Institution type & size**: Bank, fintech, MSB, BaaS sponsor, etc. — and approximate asset size or transaction volume (drives which requirements apply and thresholds)
- **Current state inputs**: Existing policies, procedures, controls, or program documents — pasted text, summaries, or a description of what exists
- **Known weak spots**: Areas the team already suspects are deficient
- **Recent regulatory activity**: Any prior exam findings, MRAs, consent orders, or audit comments
- **Scope boundary**: Full program review or a specific domain (e.g., only transaction monitoring, only governance)

If institution type or size is missing, assume a mid-size fintech with a bank partner and flag any requirements whose applicability depends on those facts.

## Instructions

### Step 1: Decompose the Framework Into Testable Requirements
Break the named framework into its discrete, citeable obligations. Do not work from a vague summary — enumerate specific requirements with their source citation.

- For each requirement, record: the **citation** (section/subsection), the **plain-language obligation**, and whether it is a **mandatory control**, a **documentation requirement**, or a **governance/oversight requirement**.
- Group requirements into the framework's natural domains. Examples:
  - **BSA/AML**: CIP, CDD/EDD, beneficial ownership, transaction monitoring, SAR filing, CTR filing, OFAC/sanctions screening, recordkeeping, BSA Officer designation, independent testing, training, risk assessment
  - **NYDFS Part 500**: cybersecurity program (500.02), policy (500.03), CISO (500.04), pen testing/vuln assessment (500.05), audit trail (500.06), access privileges (500.07), risk assessment (500.09), MFA (500.12), incident reporting (500.17), CISO annual certification (500.17(b))
  - **UDAAP**: deceptive acts, unfair acts, abusive acts, marketing/disclosure review, complaint handling, fee transparency, fair-lending intersections
- Note any threshold-dependent or exemption-eligible requirements (e.g., Part 500 limited exemptions, MSB-specific BSA obligations).

### Step 2: Assess Current State Against Each Requirement
For every requirement, classify the institution's current posture into one status:
- **Met** — control exists, is documented, and is evidenced
- **Partial** — control exists but has a defined deficiency (no evidence of operation, outdated, scope gap, or no testing)
- **Missing** — no control or documentation exists
- **Unverifiable** — claimed but no supporting documentation provided

For Partial and Unverifiable items, state precisely what is missing — distinguish a **policy gap** (the rule isn't written), a **procedure gap** (no how-to/operational detail), an **execution gap** (exists on paper, no evidence it runs), and an **oversight gap** (no testing, reporting, or governance over it).

### Step 3: Rate Each Gap by Risk
Assign every Partial, Missing, or Unverifiable item a priority using two dimensions:

- **Regulatory severity**: How likely is this to draw a finding, MRA, or enforcement action?
  - **Critical** — mandatory control central to the rule; common enforcement trigger (e.g., missing SAR procedures, no MFA, no CISO designation)
  - **High** — required control with material examiner scrutiny
  - **Medium** — required but lower-frequency finding
  - **Low** — best-practice or documentation polish
- **Remediation effort**: Quick (policy edit / weeks) / Moderate (process build / 1–2 quarters) / Heavy (system, staffing, or vendor change / 2+ quarters)

Compute a **Priority Rank** that sorts Critical-severity items first regardless of effort, then sequences the rest by severity-then-effort (favoring high-severity, low-effort "fast wins" early).

### Step 4: Build the Gap Register
Produce the core deliverable as a table, one row per gap, with columns:
`Citation | Requirement | Current Status | Gap Type | Severity | Effort | Priority Rank | Remediation Action | Suggested Owner`

The **Remediation Action** must be specific and doable — name the artifact to create or fix (e.g., "Draft and board-approve a transaction monitoring tuning procedure with documented threshold rationale"), not "improve monitoring."

### Step 5: Summarize and Sequence Remediation
- **Executive summary** (4–6 sentences): overall readiness posture, count of gaps by severity, and the single highest-risk exposure.
- **Top 5 priority actions**: the items to start this quarter, each with the gap it closes and why it ranks first.
- **Phased roadmap**: Phase 1 (0–30 days, Critical + fast wins), Phase 2 (30–90 days, High), Phase 3 (90+ days, Medium/Heavy).

## Output Format
- **Structure**: Executive summary → framework domains covered → full Gap Register table → Top 5 priority actions → phased remediation roadmap
- **Length**: 1,000–1,500 words plus the Gap Register table
- **Format**: Prose summary sections plus a structured table for the Gap Register; roadmap as phased lists
- **Sections**: Executive Summary → Requirements Decomposition (by domain) → Gap Register (table) → Top 5 Priority Actions → Phased Remediation Roadmap
- **Tone**: Compliance specialist — precise, citation-grounded, examiner-aware; no hedging, no generic risk-speak

## Quality Checklist
Before delivering output, verify:
- [ ] Every gap row includes a specific regulatory citation (section/subsection), not just the framework name
- [ ] Each gap is classified by both status (Met/Partial/Missing/Unverifiable) and gap type (policy/procedure/execution/oversight)
- [ ] Every Partial/Missing/Unverifiable item carries a severity rating with implicit or stated enforcement reasoning
- [ ] The Gap Register is sorted by Priority Rank with Critical items at the top
- [ ] Remediation actions name a concrete artifact or fix — none say only "improve" or "review"
- [ ] Threshold- or exemption-dependent requirements are flagged where applicability is uncertain

## Notes
- The most common Critical findings are missing or untested controls that exist on paper — weight execution and oversight gaps heavily, not just documentation gaps.
- When current-state input is thin, default to flagging items as **Unverifiable** rather than assuming they're Met; an examiner will treat "no evidence" the same way.
- For BSA/AML, the independent testing, risk assessment, and SAR/CTR filing controls draw the most enforcement attention — scrutinize these first.
- This analysis is a structured readiness assessment, not legal advice; recommend validation by counsel or a qualified independent reviewer before relying on it for an attestation or filing.

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## How to use this skill

This file is a Claude Code skill in [Anthropic's standard format](https://docs.anthropic.com/en/docs/claude-code/skills) — markdown with YAML frontmatter at the top.

**Installing in Claude Code:**
- `~/.claude/skills/<folder-name>/SKILL.md` — auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects)
- `<your-project>/.claude/skills/<folder-name>/SKILL.md` — auto-loads only when working in that project (recommended for project-specific skills)

Restart Claude Code or open a new session to register.

**Using in Claude.ai, ChatGPT, Gemini, or other AI tools:**

1. Drag this file into a new chat, or copy and paste its contents
2. Send your task or request as your next message — the AI will apply the skill where it fits

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