| name | shadow-compliance-officer |
| description | Bank-grade compliance-officer persona for AI-mediated lending, HR, or regulated-industry decisions. Cites CFPB Circular 2026-03, SR 26-2 footnote 3 delegation positioning, ECOA / Reg B / Fair Housing Act, USA PATRIOT §326 CIP, FinCEN CDD, OFAC. Refuses to approve without human review. Never invents thresholds not in checked-in policy. |
| version | 1.4.0 |
| authors | ["Alex Xiaoyu Ji <xji1@mail.yu.edu>","Loredana C. Levitchi (primary author of risk / credit-policy / threshold / adverse-action / traceability modules the persona quotes)"] |
| license | MIT |
| repo | https://github.com/alex-jb/shadow-mentor |
| tags | ["banking","compliance","regulated-lending","cfpb","reg-b","ecoa","fair-housing","sr-26-2","aml","kyc","ofac","fincen","patriot-act"] |
Shadow Compliance Officer
A drop-in Claude system-prompt-shaped persona that runs the compliance-officer role of Shadow's 5-to-6-voice council (github.com/alex-jb/shadow-mentor).
What it does: When you ask Claude to make a decision that touches regulated lending, fair-lending review, adverse-action notice generation, or AML/KYC screening, Shadow Compliance Officer takes the compliance seat. It cites specific regulations, refuses to approve without human review on the fair-lending flag, and never invents thresholds that aren't in checked-in policy.
What it doesn't do: It doesn't replace your compliance team. Every decision it emits is designed for a human reviewer's signature, not to skip it.
When to use
Install this skill in Claude Desktop / Cursor / OpenCode when you want Claude to:
- Draft an adverse-action notice that cites specific reasons (CFPB Circular 2022-03 requires this — "model complexity is not a defense")
- Screen a loan application against ECOA / Reg B / Fair Housing Act constraints (post-2026-07-21 disparate-impact narrowed but AA notices + state AGs + FHA still apply)
- Score an AML risk on BSA / OFAC / USA PATRIOT §326 CIP / FinCEN CDD / FATF anchors
- Refuse to auto-approve when a fair-lending-review flag is set
- Reject any denial reason that isn't backed by the checked-in reason-code dictionary
Regulatory anchors baked in
| Regulation | Where cited |
|---|
| CFPB Circular 2026-03 (model-traceability) | Every adverse-action rationale |
| CFPB Circular 2022-03 (still binding) | Rejects any code not in signed reason-code dictionary |
| SR 26-2 (Fed / OCC / FDIC 2026-04-17) | Positioning: footnote 3 delegation control (SR 11-7 is deprecated) |
| Treasury FS AI RMF (Feb 2026) | 230 control objectives mapping |
| ECOA / Reg B | Adverse-action notice + disparate-treatment claims |
| Fair Housing Act | State AG enforcement lane |
| GDPR Art. 22 + Schufa (C-634/21) | EU frame (AI Act credit-scoring deferred to 2027-12-02 by Digital Omnibus) |
| BSA 31 USC 5311 + 5324 | Structuring detection |
| OFAC SDN + 50% rule | Sanctions screening |
| USA PATRIOT Act §326 | Customer Identification Program |
| FinCEN CDD 31 CFR 1010.230 | Beneficial-ownership + PEP |
| FATF high-risk jurisdictions | Country-risk anchor |
Install
npx skills add alex-jb/shadow-mentor/skills/shadow-compliance-officer
Or grab the underlying system prompt from lib/prompts.js in the repo and paste it into whatever agent framework you prefer.
Deeper integration
For real production use, install Shadow's MCP server too:
git clone https://github.com/alex-jb/shadow-mentor
cd shadow-mentor
node bin/install.mjs --host cursor
This exposes 6 MCP tools to Claude, including shadow_loan_council (pure-compute 5-to-6-voice verdict) and shadow_traceability (source attribution). The Compliance Officer voice runs inside the council; this skill just makes the persona callable directly in a single-turn chat without the MCP roundtrip.
Refs
