Policy Gap Analysis
Real-time review of your policies
Kalipso continuously checks your policies against the regulations that apply to you, flags exactly where you’re exposed, and proposes the compliant wording to fix it.
AML/CFT Policy — UBO Identification
AnalyzingWhere the customer acts within a fiducie (Art. 2011 Civil Code), the beneficial owner is identified by role under Art. R.561-3-0 CMF.
Where no beneficial owner can be identified, the senior managing official of the fiduciaire is recorded as the beneficial owner by default (fallback under Art. R.561-1 CMF).
Where no beneficial owner of a fiducie can be identified under Art. R.561-3-0 CMF, the firm shall terminate the relationship under Art. L.561-8 CMF. The senior-management fallback applies only to sociétés.
How it works
From a clause to a compliant redline
- 01
Scan against the obligations in scope
Every clause is checked against the regulations that actually bind your firm — not a generic checklist.
- 02
Pinpoint the gap
The exact wording that breaches an obligation is flagged, tied to the article it fails — not a vague risk score.
- 03
Draft the compliant redline
You get editable wording that satisfies the law, with the rationale and a link to source — ready to defend.
The same gap in full, as it appears for review — with the proposed redline:
AML/CFT Internal Policy — UBO Identification
3.4 Identification of Beneficial Owners — Fiducies
Where the customer acts within the framework of a fiducie within the meaning of Art. 2011 of the Civil Code, or any comparable foreign trust-like arrangement, the beneficial owner shall be identified by role in accordance with Art. R.561-3-0 CMF: the constituant(s), fiduciaire(s), bénéficiaire(s), and any tiers protecteur. Art. R.561-3-0 contains no senior management fallback provision.
Where no beneficial owner of a fiducie can be identified under the above criteria, the natural person(s) holding the position of senior managing official(s) of the fiduciaire shall be recorded as the beneficial owner by default, in accordance with the fallback procedure under Art. R.561-1 CMF.
Where no beneficial owner of a fiducie can be identified under Art. R.561-3-0 CMF, the firm shall not enter into a business relationship or shall terminate the existing relationship in accordance with Art. L.561-8 CMF. The senior management fallback is defined under Art. R.561-1 CMF and applies only to corporate entities (sociétés). Art. R.561-3-0 CMF does not permit any fallback to senior managing officials for fiducies.
Art. R.561-1 CMF (senior management fallback) applies exclusively to sociétés. Art. R.561-3-0 CMF governs fiducies and contains no fallback — failure to identify the UBO must strictly result in refusal of the business relationship under Art. L.561-8 CMF.
In all cases, the firm shall additionally identify any natural person who directly or indirectly holds more than 25% of the assets, rights, or securities included in the patrimoine fiduciaire, per Art. R.561-3-0 CMF.
For each gap, you get
The issue
A prioritised list of gaps, each tied to the specific obligation it breaches — not a vague risk flag.
The fix
Editable redlines with compliant wording — insertions and deletions, every change tracked in the platform.
The rationale
Why the new wording satisfies the law, with a direct link to source for verification and audit defence.
The outcome
A clear path to remediation, end to end. You finish with a compliant policy — not an analysis, a report or a memo.
“You don’t end with a list of problems. You end with a compliant policy — every change tracked and traced to source, ready to defend in an audit.”
One continuous workflow
Detect, map, assess — same platform, same data, same audit trail
No handoffs, no lost context. Each module passes its work to the next, all of it supported by Compliance Chat.
See a gap analysis on your own policies
Request a walkthrough and we will show you how Kalipso monitors regulatory change, maps it to your obligations and tracks every gap to closure — on your own regulatory scope.