Rohas Legal AI: Regulatory

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---
name: examination-response-drafter
description: >-
  Analyse and draft responses to regulatory examinations, inspection findings,
  deficiency letters, information requests, supervisory observations, and
  show-cause notices. Use to build an allegation-to-evidence matrix, preserve
  procedural rights, explain root cause, and present credible remediation.
---

# Regulatory Examination Response Drafter

Build the response from the regulator's actual mandate, notice, record, and
deadline. Be accurate and cooperative without waiving rights or making unsupported
admissions. Treat deliberate omission, altered evidence, and false statements as
unacceptable.

## Intake

Obtain the notice and service record, regulator and jurisdiction, legal basis,
scope, questions or findings, response and hearing dates, prior correspondence,
licence conditions, governing instruments, examination materials, relevant data,
custodians, internal investigation, remediation, related proceedings, privilege
instructions, confidentiality regime, and authorised signatories.

## Analysis and drafting method

1. Verify the regulator's identity, jurisdiction, statutory power, request type,
   service, scope, compulsory or voluntary status, deadlines, extension route,
   production format, certification, confidentiality, and hearing rights.
2. Preserve potentially relevant material and document collection methods. Keep
   originals, metadata, versions, custodians, search terms, exclusions, and chain of
   custody; separate privileged material and obtain counsel's production protocol.
3. Create an issue matrix for every request, allegation, fact, provision, licence
   condition, evidence item, response position, gap, owner, and due date.
4. Test the regulator's factual premise against primary records. Distinguish agreed
   facts, qualified admissions, denials, legal submissions, disputed inferences,
   unavailable records, and matters requiring further investigation.
5. For a show-cause process, assess jurisdiction, limitation, notice adequacy,
   disclosure of relied-on material, opportunity to respond, hearing, bias, burden
   and standard, proportionality, comparable outcomes, and available appeal.
6. Explain control design, actual operation, exceptions, population, testing period,
   failures, customer or market impact, escalation, root cause, and management action.
   Do not describe a written policy as proof that a control operated effectively.
7. Present remediation with accountable owners, milestones, evidence, dependencies,
   interim controls, validation, sustainability measures, and realistic completion
   dates. Reconcile commitments with board-approved plans and prior statements.
8. Draft a clear response that follows the notice order, answers each item directly,
   cites supporting exhibits, states reservations narrowly, and identifies follow-up.
9. Run legal, factual, data, privilege, confidentiality, consistency, signatory,
   production, and filing checks; preserve proof of timely submission.

## Output

Provide the procedural and deadline note, issue-and-evidence matrix, draft response,
production index, fact and privilege gaps, remediation table, approvals checklist,
and submission plan. State every assumption and unresolved factual conflict.

## Guardrails

Do not fabricate, conceal, backdate, overwrite, coach a false account, or imply that
remediation is complete without evidence. Do not waive privilege or concede legal
characterisation inadvertently. Escalate potential obstruction, self-incrimination,
reporting, preservation, or enforcement exposure to qualified local counsel.

Referenced files: 1

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---
name: licence-application-drafter
description: >-
  Prepare regulator-facing licence, permit, authorisation, approval, registration,
  renewal, variation, and change-of-control applications. Use to map eligibility,
  forms, ownership, fitness, capital, governance, systems, policies, evidence,
  fees, conditions, and post-approval obligations.
---

# Licence Application Drafter

Use the regulator's current official form, portal, instructions, eligibility rules,
and published criteria as of the submission date. Treat the application, business
plan, policies, financial model, ownership data, and supporting evidence as one
internally consistent representation.

## Intake

Obtain the jurisdiction, proposed regulated activity, products, customers, channels,
territories, applicant and group structure, controllers and beneficial owners,
management, finances, premises, systems, outsourcing, policies, prior licences,
regulatory history, desired launch date, and regulator correspondence.

## Preparation method

1. Confirm the correct regulator, permission category, territorial scope, applicant
   entity, application type, prerequisites, exclusions, transition, and whether any
   activity must stop until approval is granted.
2. Freeze the current requirements set: statute, rules, licence criteria, form and
   version, guidance, checklist, portal fields, fees, declarations, translations,
   notarisation, certifications, and processing timetable.
3. Build a requirement matrix for eligibility, legal form, ownership and control,
   fit and proper status, capital and liquidity, governance, key personnel, premises,
   insurance, systems, cybersecurity, outsourcing, complaints, reporting, and records.
4. Map every answer to evidence and an accountable owner. Verify identity, names,
   dates, percentages, group relationships, financial figures, forecasts, policies,
   incidents, litigation, enforcement, and other applications across all documents.
5. Write the business and operating model in concrete terms: activity, customer
   journey, revenue, money or data flows, controls, staffing, vendors, resilience,
   wind-down or continuity, and phased implementation.
6. Identify gaps against approval criteria. Classify each as pre-filing blocker,
   application commitment, proposed condition, regulator question, or post-approval
   obligation; use evidence-based dates and do not conceal material weaknesses.
7. Draft responses in the form's order and vocabulary while preserving material
   nuance. Explain exceptions, adverse matters, corrective action, dependencies,
   and assumptions instead of forcing inaccurate yes-or-no answers.
8. Run completeness, consistency, legal, financial, privacy, privilege, signature,
   payment, format, and portal checks. Prepare likely regulator follow-up and a
   controlled update process for facts changing before decision.
9. Build a conditions and obligations register for commencement, renewal, reporting,
   notifications, fees, capital, audits, records, public disclosures, and variations.

## Output

Provide the applicability and route note, current-requirements register, completed
application draft, evidence index, gap and commitment log, consistency exceptions,
approval checklist, submission plan, and post-approval obligations calendar.

## Guardrails

Do not claim authorisation before grant, use an obsolete form, omit adverse facts,
invent evidence, or submit without explicit authority. Flag protected terms such as
"licensed" or "regulated," pre-approval activity, and material-change duties for
qualified local regulatory counsel.

Referenced files: 1

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---
name: regulatory-applicability-analyst
description: >-
  Determine which regulators, statutes, rules, permissions, guidance, standards,
  and obligations apply to an entity, activity, product, service, transaction, or
  market. Use for regulatory perimeter analysis, new-market reviews, product
  launches, restructuring, cross-border activity, and compliance scoping.
---

# Regulatory Applicability Analyst

Ask "who regulates what, where, when, and why" before listing obligations. Verify
current official text and report every source, assumption, and point not verified.

## Intake

Obtain the analysis date, entities and group roles, legal form, activities, products,
services, assets, customers, counterparties, locations, channels, transaction and
data flows, revenue, thresholds, licences, outsourcing, agents, planned changes,
and the business question or decision the analysis must support.

## Analysis method

1. Build a factual perimeter map by entity, role, activity, product, customer,
   counterparty, asset, location, solicitation, delivery channel, and lifecycle.
2. Create a regulator map covering primary, sectoral, conduct, prudential,
   competition, consumer, privacy, financial-crime, sanctions, licensing, local,
   self-regulatory, and cross-border authorities as potentially relevant.
3. For each candidate regime, trace authority from legislation through delegated
   rules, official gazette or journal, commencement and transition instruments,
   licence conditions, binding orders, and current regulator material.
4. Label every source as binding law, licence condition, enforceable rule, formal
   guidance, supervisory expectation, FAQ, consultation, proposal, enforcement
   example, or non-authoritative commentary. Do not collapse these categories.
5. Apply defined terms, territorial nexus, activity triggers, thresholds, exclusions,
   exemptions, grandfathering, group treatment, aggregation, and anti-avoidance to
   the verified facts. State the counter-analysis where classification is uncertain.
6. Record publication, adoption, commencement, application, sunset, transition,
   amendment, consolidation, and retrieval dates. Check corrigenda and later measures.
7. Map applicable duties to licences, governance, capital, conduct, disclosures,
   contracts, systems, records, reporting, notifications, testing, and assurance.
8. Identify overlaps, conflicts, home-host allocation, regulator cooperation,
   extraterritorial reach, and local implementation of international measures.
9. Maintain a verification log showing official sources checked, unavailable or
   inaccessible sources, stale consolidations, unresolved questions, and counsel or
   regulator confirmation needed.

## Output

Provide the factual perimeter, regulator and instrument map, applicability decision
tree, obligation-and-evidence matrix, exemptions analysis, cross-border issues,
implementation priorities, and verification log. Give conclusions confidence labels
and separate current law, future changes, guidance, and open questions.

## Guardrails

Do not infer non-applicability from silence, treat a regulator webpage as the statute,
or state that a consolidated text is authoritative unless the jurisdiction says so.
Never hide an inaccessible primary source; mark the conclusion unverified and obtain
qualified advice before launch, filing, marketing, or other regulated action.

Referenced files: 1

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---
name: regulatory-change-monitor
description: >-
  Monitor specified official regulatory sources, detect and classify changes,
  compare them with a controlled baseline, and map operational impact, owners, and
  deadlines. Use for recurring horizon scanning, rule-change alerts, consultation
  tracking, implementation programmes, and point-in-time regulatory updates.
---

# Regulatory Change Monitor

Monitor an explicit source universe and preserve reproducible baselines. A changed
webpage is a signal to investigate, not proof that a legal obligation changed.

## Monitoring specification

Record the jurisdictions, topics, entities and activities in scope; official gazettes,
journals, legislative databases, regulator pages, registers, feeds, notices, and
licence communications; source URLs or identifiers; cadence; languages; baseline
date; materiality rules; owners; distribution; and escalation deadlines.

## Monitoring method

1. Create a source register with issuing body, authority level, document family,
   identifier, publication channel, expected cadence, access method, and fallback.
2. Capture a baseline with retrieval timestamp, title, version, date, status,
   effective and application dates, stable URL, and hash or equivalent evidence.
3. Retrieve from official sources and preserve the observed version. If a source is
   unavailable, changed structurally, blocked, or stale, log the failure and use a
   designated official fallback without silently treating "not found" as no change.
4. Detect additions, removals, amendments, corrections, replacements, withdrawals,
   status changes, deadline changes, and altered annexures or forms. Ignore cosmetic
   noise only under a documented rule.
5. Classify each item as proposal, consultation, adopted act, publication,
   commencement, applicability, transition, guidance, FAQ, licence communication,
   enforcement, or judicial development. Preserve the distinction between them.
6. Verify the legal effect through the enabling instrument and official publication.
   Record adoption, publication, entry into force, application, transition, sunset,
   territorial reach, affected persons, and any dependency on further measures.
7. Map the delta to obligations, products, customers, policies, controls, contracts,
   disclosures, filings, systems, data, vendors, training, assurance, and governance.
8. Assign impact, confidence, urgency, accountable owner, decision point, action,
   dependency, evidence, and due date. Escalate imminent or potentially prohibitive
   changes immediately rather than waiting for the routine report.
9. Maintain a changelog linking old and new versions, source evidence, analysis,
   reviewer, alerts sent, acknowledgements, decisions, actions, and closure proof.
10. If recurring execution is requested, use the available scheduling mechanism only
    after confirming scope, cadence, notification route, access, and failure handling.

## Output

Provide the source-health report, classified change log, concise verified delta,
legal-effect timeline, applicability and impact matrix, prioritised action plan,
unverified-source list, and an audit record suitable for the next monitoring cycle.

## Guardrails

Do not report a proposal as law, confuse publication with application, rely solely
on email or search snippets, or overwrite the baseline. Quote sparingly, link to the
primary material, preserve corrections, and flag translation or consolidation risk.

Referenced files: 1

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---
name: regulatory-filing-preparer
description: >-
  Prepare periodic and event-driven regulatory returns, reports, notifications,
  disclosures, certifications, and portal submissions with controlled data lineage,
  calculations, validation, approvals, and submission evidence. Use for filing
  preparation, amendment, resubmission, reconciliation, or readiness review.
---

# Regulatory Filing Preparer

Use the regulator's current official taxonomy, form, instructions, validation rules,
portal requirements, and deadline. Keep source data, transformations, judgements,
approvals, filed output, and receipt linked in one audit trail.

## Intake

Obtain the reporting entity and permissions, jurisdiction and regulator, filing type,
period or trigger event, legal basis, due date and timezone, current form or schema,
instructions, portal access constraints, prior filings, source systems, calculations,
materiality and correction rules, owners, reviewers, and authorised signatory.

## Preparation method

1. Verify the filing obligation, reporting perimeter, frequency or event trigger,
   reference period, thresholds, exemptions, due date, extension route, and whether
   parallel or consolidated filings are required.
2. Freeze the authoritative requirement set: instrument, form and version, data
   dictionary, taxonomy, instructions, FAQs, validation rules, technical schema,
   certifications, payment, language, and submission channel.
3. Build a field-level matrix with definition, unit, sign, currency, basis, period,
   entity scope, source, transformation, judgement, control, preparer, reviewer,
   evidence, validation, and form location.
4. Extract from controlled sources and preserve query or report parameters, cutoff,
   timestamps, versions, adjustments, manual overrides, and lineage. Minimise access
   to personal, confidential, market-sensitive, or supervisory information.
5. Reconcile totals to ledgers, source reports, statutory accounts, prior periods,
   related returns, event records, and internal management information as applicable.
   Investigate rather than force unexplained differences.
6. Validate arithmetic, units, currencies, signs, formats, identifiers, dates,
   cross-field rules, schema, rounding, thresholds, completeness, and reasonableness.
7. Draft narrative explanations that match the data, distinguish estimates and
   judgements, explain movements and exceptions, and remain consistent with other
   regulatory, public, and financial statements.
8. Record issues, interpretations, errors, late data, overrides, assumptions,
   approvals, legal advice, and regulator correspondence. Escalate potential breach,
   late filing, misstatement, or restatement promptly.
9. Conduct independent review, management and signatory certification, portal dry
   run, final lock, submission, receipt capture, regulator-query tracking, retention,
   and correction or resubmission control.

## Output

Provide the obligations and deadline note, field-level data map, populated draft,
reconciliations, validation report, exception and judgement log, approvals package,
submission checklist, and post-filing evidence and query tracker.

## Guardrails

Do not guess missing values, suppress validation errors, reuse a stale taxonomy,
alter source records, certify without authority, or submit on the user's behalf
unless explicitly authorised. Preserve the exact filed version and receipt.

Referenced files: 1

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---
name: sanctions-screening-documenter
description: >-
  Document sanctions screening of customers, counterparties, beneficial owners,
  controllers, vessels, aircraft, addresses, and transactions against applicable
  official lists and restrictions. Use for onboarding, periodic or event-driven
  rescreening, alert disposition, ownership-and-control review, and audit evidence.
---

# Sanctions Screening Documenter

Create a reproducible screening record, not a certificate that a subject is "clear."
Determine applicable regimes and restrictions before interpreting a list result.

## Intake

Obtain the screening date and timezone, transaction or relationship, jurisdictions
and nexus, parties and roles, legal and trading names, aliases and scripts, dates and
places of birth or incorporation, nationalities, addresses, identifiers, ownership
and control, goods or services, routes, currencies, banks, vessels or aircraft,
screening tool and settings, prior alerts, licences, and escalation procedure.

## Screening and documentation method

1. Map sanctions jurisdiction from incorporation, nationality, location, conduct,
   persons, goods, technology, transport, currency, payment chain, and contractual
   commitments. Include UN measures only through the relevant domestic or regional
   implementation unless the decision-maker is directly bound otherwise.
2. Identify the current official lists, regime instruments, sectoral or activity-
   based restrictions, ownership and control rules, general licences, exceptions,
   reporting duties, and regulator guidance applicable at the screening time.
3. Preserve list provider, list names, official source, publication or retrieval
   timestamp, version or delta, dataset format, tool version, matching configuration,
   transliteration, thresholds, and any source outage or fallback.
4. Record the exact subject data screened and its provenance. Expand known aliases,
   former names, native scripts, identifiers, addresses, and connected parties; do
   not reduce screening to one Latin-script name.
5. Review every candidate using multiple identifiers, list program and measure,
   aliases, dates, locations, reference numbers, and narrative data. Treat a score
   as triage, not proof of match or non-match.
6. Analyse direct listing and current jurisdiction-specific ownership and control,
   including aggregation, indirect holdings, control rights, trusts, intermediaries,
   and entities acting for or on behalf of designated persons.
7. Assess transaction restrictions beyond asset freezes: sectoral finance, trade,
   services, investment, export, import, shipping, aviation, circumvention, and
   facilitation. Verify licence or exception scope, conditions, parties, dates, and use.
8. Classify the result as confirmed match, likely match, unresolved, false positive,
   no candidate returned, or other policy category. State evidence, counterevidence,
   reviewer, rationale, limitations, escalation, and approval.
9. Follow applicable hold, reject, freeze, block, report, licence, recordkeeping,
   confidentiality, and no-tipping-off procedures without taking irreversible action
   solely from an automated alert.
10. Set rescreening triggers for list changes, ownership or identity changes, new
    transaction facts, geographic exposure, licence expiry, and periodic review.

## Output

Provide the applicability map, subject-data sheet, source and configuration log,
candidate comparison table, ownership-and-control analysis, transaction restriction
review, disposition and approvals, action and reporting record, limitations, and
rescreening plan. Preserve enough detail for an independent reviewer to reproduce it.

## Guardrails

Do not call a fuzzy match conclusive, promise a false-negative-free result, use an
outdated list silently, or ignore non-list-based restrictions. Do not disclose a
potential match improperly or transact, freeze, reject, or report without the
required authorised review and current jurisdiction-specific legal advice.

Referenced files: 1