25.7% → 5.3% Insufficient coverage reduced
35.4% → 45.7% Comprehensive coverage achieved
61.7% → 74.9% Average coverage score
~100 lines Policy changes by Head of Compliance

The Firm and the Challenge

The firm is a Jersey-based AML regulated business in financial services. The compliance team had built AML/CFT procedures over time, but the link between regulatory requirements and those procedures had never been mapped or scored. No one could see the gaps. The alternatives were a £2,000 consultant producing a one-time snapshot, or up to 60 person-days of internal effort with no structured output.

The GapSure Approach

GapSure mapped the firm's existing policies and procedures against a verified regulatory knowledge base, scored every obligation (Comprehensive, Adequate, Partial, Insufficient, or None), and generated AI-drafted improvements for the Head of Compliance to review and approve. Every proposed change went through the Head of Compliance before being incorporated. Each change was tracked with a full audit trail: what was changed, why, which regulatory requirement it addressed, and who approved it.

Results

Before the pilot, more than a quarter of the firm's AML/CFT obligations were rated Insufficient. After the Head of Compliance reviewed and approved the recommended improvements, Insufficient coverage dropped to 5.3%. Comprehensive coverage rose from 35.4% to 45.7%. The overall average coverage score improved from 61.7% to 74.9% across all mapped obligations. About 100 lines of targeted policy changes produced these results. No wholesale rewrites. The remaining Insufficient areas were documented and placed on a tracked remediation timeline.

“GapSure showed us exactly where our procedures fell short — and gave us the language to fix them. We reviewed everything, approved the changes we agreed with, and ended up with stronger procedures and a complete audit trail. That’s what defensible looks like.”

Head of Compliance

The Cost Comparison

  • External consultant: ~£2,000 for a one-off, one-page report. No obligation-level mapping, no procedure improvements, no way to update when regulations change.
  • Internal manual effort: Up to 60 person-days. No structured gap analysis, no coverage scores, no audit trail.
  • GapSure: Obligation-by-obligation mapping, coverage scores, AI-drafted procedure improvements reviewed and approved in the same workflow. Improved procedures, audit trail, and gap analysis in one place.

What Happened Next

The firm now has a verified baseline. When the regulator asks “how do you know your procedures cover your AML/CFT obligations?” the Head of Compliance can point to the assessment, the coverage categories, the specific improvements made, and the approval trail for each change.

When AML/CFT requirements change, the team can see which obligations are affected, how existing coverage maps against the new requirements, and where procedures need updating. Instead of starting from scratch, they update from a known position and keep a consistent audit trail across every change cycle.

Key Takeaways

  • Insufficient coverage reduced from 25.7% to 5.3% through collaborative, verifiable improvements
  • ~100 targeted policy changes produced stronger procedures without wholesale rewrites
  • The full audit trail (what changed, why, and who approved it) is the foundation of defensible compliance
  • Manual alternatives (£2,000 consultant or 60 person-days) lack the obligation-level mapping, gap analysis, and procedure improvements the team got from GapSure

Find gaps. Close them. Prove it.

See what GapSure can do for your firm’s compliance coverage.