METHODOLOGY
Every finding traced to its source. Every source weighted by its legal authority. No interpretive shortcuts.
DAC applies a four-tier hierarchy to every regulatory requirement we map. This hierarchy determines the weight and urgency of each finding in your Readiness Snapshot and Platform analysis. A Tier 1 finding (binding statute) is treated with greater severity than a Tier 4 finding (emerging proposal) — because an examiner will do the same.
Why this matters: When you receive a Readiness Snapshot, every finding is tagged with its tier. A finding based on a binding CFR provision carries different weight than one based on enforcement patterns. This distinction is critical for prioritizing remediation — and for defending your compliance program during an examination.
Within each tier, DAC classifies requirements by their source type. This classification appears in your workpapers and portal, allowing you to filter and prioritize your regulatory map.
DAC is a regulatory logic mapping platform. We map which requirements likely apply to your business based on your entity type, licenses, jurisdictions, and activities. We trace every finding to its source regulation, weight it by the Hierarchy of Authority, and deliver it in audit-ready format.
DAC does not provide legal advice, render legal opinions, or guarantee compliance. We are not a law firm. We do not act as outside counsel. Our analysis is a decision-support tool that gives your compliance team and legal counsel a defensible, source-cited baseline to work from — not a substitute for either.
Our database spans federal, state, and international regulatory frameworks. Each anchor is classified by its current operational status:
| ANCHOR | SCOPE | REQS | STATUS |
|---|---|---|---|
| FinCEN | BSA/AML — Registration, SAR/CTR, Travel Rule | 21 | LIVE |
| OFAC | Sanctions — SDN screening, wallet blocking, Tornado Cash | 16 | LIVE |
| NYDFS | BitLicense (Part 200) + Cybersecurity (Part 500) | 24 | LIVE |
| SEC | Securities registration, broker-dealer, custody, tokenization | 20 | LIVE |
| CFTC | Derivatives, commodity trading, FCM requirements | 18 | LIVE |
| OCC | National bank custody, trust charter, IL 1183 | 18 | LIVE |
| CFPB | Regulation E — fiat electronic fund transfers, error resolution, disclosures | 6 | LIVE |
| State MTL | Multi-state money transmitter licensing and AML | 18 | LIVE |
| CA DFAL | California Digital Financial Assets Law (DFPI) | 15 | PREVIEW |
| EU MiCA | Markets in Crypto-Assets — EU-wide framework | 18 | PREVIEW |
| Token Taxonomy | SEC/CFTC Joint Interpretation — digital asset classification (March 2026) | 11 | LIVE |
| GENIUS Act | Payment stablecoin — reserves, redemption, certification (signed law, effective ~Jan 2027) | 9 | SIGNED LAW |
| SMART Act | SEC-CFTC coordination — inter-agency data sharing | 5 | STRATEGIC WATCH |
Status definitions: LIVE = fully mapped, source-cited, included in Snapshot analysis. PREVIEW = requirements mapped but framework is newly enacted or not yet fully enforced; findings are flagged as preview in reports. STRATEGIC WATCH = proposed or pending legislation tracked for planning purposes only; not represented as current obligations.
When you engage DAC for a Readiness Snapshot, the process follows a structured methodology:
1. Intake: You complete the regulatory exposure questionnaire — entity information, licensing status, business activities, and targeted compliance questions for each applicable regulator.
2. Mapping: Your responses are mapped against our 199-requirement database across 13 regulatory anchors. Only the requirements applicable to your entity type, licenses, jurisdictions, and activities are included in your analysis. Each applicable requirement is classified by tier, type, and risk area. Requirements from Preview and Strategic Watch anchors are clearly flagged as such.
3. Gap Analysis: We compare your stated compliance posture against the mapped requirements to identify gaps — areas where your current program does not satisfy the applicable obligation.
4. Deliverable: You receive a board-ready report (.docx) with an executive summary, prioritized findings with risk ratings and source citations, a remediation priority matrix, and a cited requirement map. Every finding is traceable to the specific regulation, guidance, or enforcement pattern that supports it.
5. Credit: 100% of your Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.
Practitioner-Built Compliance Infrastructure
DAC is built and operated by compliance practitioners — not consultants, not legal theorists, not software developers who read about compliance. The team behind DAC brings Certified Crypto Auditor credentials and over a decade of hands-on experience across federally regulated financial institutions, clearinghouses, and mortgage lending environments.
That operational background is why DAC's methodology reflects how examiners actually conduct reviews — not how compliance is taught in textbooks. The Hierarchy of Authority, the severity classifications, the MRA/MRIA-format gap analysis — these come from years of sitting across the table from examiners and knowing what they look for, how they document findings, and what a defensible response looks like.
DAC is not a law firm. We don't provide legal advice. What we provide is a system-driven regulatory map that gives compliance officers a defensible, source-cited view of where their program stands — so they can make informed decisions with their legal counsel, not in the dark.
System Integrity
Every requirement in our database has been individually validated against its primary source — the actual CFR provision, NYCRR section, or agency guidance document. We do not rely on secondary summaries, third-party compilations, or general knowledge. If we cite 31 CFR 1022.210, we've read 31 CFR 1022.210. No sensitive policy documents are stored on our servers. Analysis is performed via deterministic intake and real-time mapping against our audited database.
12 questions. 199 deterministic requirements. No signup required.
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