AI Adoption & Governance · Fixed Scope
A fixed-scope engagement for banks and financial institutions that already have AI in production or close to it. It maps your AI use against the 230 control objectives of the CRI Financial Services AI Risk Management Framework, cross-referenced to NIST AI RMF, ISO 42001, the EU AI Act and the other instruments in the cross-framework map, and tells you which gaps matter first.
Why now. Generated work is fluent whether or not it is correct. Any control that relies on a reviewer noticing that something looks off is weaker than it was, and most control inventories were written before that was true.
The diagnostic finds those controls and recommends a mechanism outside the thing being checked.
Phase one
Scope and inventory
Agree which business lines and AI uses are in scope. Build or validate the inventory of AI systems, including generative tools used inside existing processes, with an accountable owner for each.
Phase two
Applicability and gaps
Determine which of the 230 objectives apply at your adoption stage, then test current policies, controls and evidence against them. Every control that depends on human review of generated output is flagged separately.
Phase three
Roadmap and readout
A sequenced remediation roadmap with owners, and an executive readout that separates what must change before the next deployment from what can follow.
1
AI use inventory
Systems, uses, owners and adoption stage, in one register.
2
Gap analysis
Applicable objectives, current state and evidence, cross-referenced to the frameworks you report against.
3
Review-dependent controls
The controls weakened by fluent generated output, and a recommended replacement mechanism for each.
4
Remediation roadmap
Sequenced, owned and sized, with an executive readout.
Bharath Subramanya, founder of Invictera. Twenty plus years of enterprise delivery, including bank M&A integration, core-banking go-live readiness and a commercial-lending center of excellence, and firsthand operation of six AI-built products in production. Author of the cross-framework map.
The diagnostic is an operating and control-design review. It is not legal or regulatory advice, second-line model validation, or an audit opinion, and it works alongside your legal, risk and audit functions rather than in place of them. It does not certify compliance with any framework or regulation. Scope, duration and fee are fixed in a signed statement of work.
Six questions, two minutes, and a first view of which objectives apply to you.
Or write to hello@invictera.com.