Governance architect

Every obligation needs a path to the ground.

In most large banks, regulations, policies, risks, controls and evidence each live with a different team, in a different system, under a different taxonomy. I build the line that connects them: a new way of working for risk and control functions, shared by the first line, the second line and internal audit. 20+ years doing it at Goldman Sachs, Morgan Stanley, Moody's, MUFG, Wells Fargo, BNY Mellon and American Express.

Explore the method See the track record Read the papers

300+

regulations mapped into one tracker at Wells Fargo

2

firmwide Codes of Conduct authored, at Goldman Sachs and BNY Mellon

40,000+

controls rationalized with NLP at BNY Mellon, cutting duplication by about 15%

The problem

Every function holds one piece. No one holds the line between them.

At a global systemically important bank, staying compliant is split across functions that rarely share a data model. Each one does its job well, in its own system and its own taxonomy. The failures happen in the gaps between them.

Regulatory compliance

Keeps the inventory of obligations.

Policy office

Writes, approves and attests the policies.

Operational risk

Owns the risk taxonomy and the RCSA.

Controls and testing

Designs, tests and certifies the controls.

Risk reporting

Tracks indicators and loss events.

Audit and issues

Logs findings and tracks remediation.

So when an examiner asks how a rule is met, the answer takes weeks of spreadsheets, meetings and reconciliation. When a rule changes, no one can say quickly which policies, controls and evidence it touches. And when something breaks, each function can show its own piece was in order.

A new way of working for risk and control functions

Not another system and not another committee. One line, from rule to proof, that every function works from and keeps current.

One line of sight

Every link from regulation to evidence is connected, so a question about any one of them can be answered from all the others.

A shared structure, not a shared system

Each function keeps its own tools. The chain maps between their taxonomies, so nothing has to be rebuilt to be seen.

Gaps show up early

A regulation with no control, or a control with no evidence, appears as a broken link on your own map before it appears in an exam finding.

Built for all three lines of defense

One chain, three lines, the same view.

Today each line builds its own map of the same risks. With the chain, the first line, the second line and internal audit work from one structure. Each keeps its own role and its independence. None has to rebuild the map.

First line

Business and control owners

See which obligations each control carries, what breaks if it fails, and which indicators and evidence prove it works.

Second line

Risk and compliance

Trace every regulation through policy and risk to the controls that meet it, and challenge coverage gaps and single points of failure with one view.

Third line

Internal audit

Test the same chain end to end, trace any obligation to its evidence in minutes, and send findings back in as control weaknesses with owners.

The method

Eight links that cross every function's boundary. When a control fails, the chain shows which link gave way, which team held it, and what would have held.

Open the full method

Case library

Public enforcement events mapped link by link, broken links in red.

The graph

Every case and shared thread as one network you can explore or download.

Stress test

Run 1,000 events through a chain and see where it gives way.

How it works

Top down, a graph underneath, and a loop back from every failed test.

One method, every risk type

The same eight links, applied domain by domain. Because every chain shares one structure, a control that serves several risk types is recorded once and seen by every team that relies on it.

New

AI governance

EU AI Act, NIST AI RMF, SR 11-7, NYC Local Law 144 and state AI laws, traced to evidence.

10 regulations · 14 requirements

Third-party risk

From outsourcing rules to the vendor evidence that proves oversight.

14 laws · 7 jurisdictions

Human capital

Employment law across the US, UK, EU, India, Australia, Canada and Singapore, including AI in hiring.

27 regulations · 6 groups

Data risk

Privacy, security and records rules mapped to the controls that satisfy them.

7 scenarios

Financial crime and fraud

APP scams, account takeover, synthetic identity, deepfakes, insider and conduct risk.

Change management

How a change in processing or technology flows back through the chain.

Tools

Built to run in a single file, in the browser, with nothing to install. The stress test is live on the method page.

Bank agent access mapNew

Which banks and card networks let outside AI agents into customer accounts, who carries the loss, and the controls that follow.

Risk brain

Query every case in SQL, right in your browser: where chains break, which controls fail, and which rules share them.

Stress-test simulator

Severity, containment and scrutiny as levers. A teaching model, not a forecast.

Schema and taxonomyComing soon

The chain schema and controlled tag vocabulary, to be published openly.

Let's connect

Trying to connect compliance, risk and controls data that lives in separate teams and systems? I'd enjoy comparing notes.

anand@satchit.net LinkedIn