AML Program Gap Review

AML Program Gap Review

Purpose

Produce a structured, review-ready draft gap review of an anti-money-laundering compliance program's documentation. The skill inventories the program document set, extracts the required program elements from the framework the user supplies — the firm's own program policy or a regulatory framework document (for example, a five-pillar structure where the user's framework names it) — maps each required element to where the program documents address it, classifies documentation coverage, and builds a gap matrix with verification items.

This skill provides workflow discipline and analytical structure. It produces draft work product for review by the firm's compliance function and a supervising attorney. This is not legal advice and not a compliance determination. The skill never asserts that the program complies with, or violates, any law or regulation — it records where the documentation does and does not address the elements the supplied framework defines, and routes every legal-sufficiency question to counsel.

Use When

• A user says "gap-check our AML program," "map our BSA program against the pillars in our policy," or "review these program documents against this framework."
• A firm is preparing for an examination, an independent test, or an internal audit and needs its program documentation organized against a defined element structure first.
• A compliance officer needs a structured first-pass coverage map before deciding where to remediate.
• A program document set has grown across versions and owners and needs a documentation-coverage baseline.

Required Inputs

• The program document set: the actual documents — uploaded or pasted. Typically the program policy, the AML/financial-crime risk assessment, CDD/KYC procedures, transaction-monitoring and screening procedures, training materials or records, independent testing or audit reports, and governance documents such as the compliance-officer designation. If no document set is provided, stop and request it.
• The framework defining the required elements: the firm's own program policy where it defines the program's required elements, or a user-supplied regulatory framework document. If no framework is provided, stop and request it. Do not construct required program elements from model background knowledge — the element list must come from a provided document.
• Jurisdiction and regime context: the jurisdiction(s) and regulatory regime the program operates under. If unknown, flag [verify jurisdiction] and state how the gap analysis is limited without it. The skill is jurisdiction-neutral; it applies whatever framework the user supplies and asserts nothing about the law of any jurisdiction.
• Prior findings (optional): prior examination, audit, or independent-testing findings, so open findings can be cross-referenced to the gaps.