<!-- last-reviewed: 2026-06-01 · owner: Legal & Compliance (Compliance Analyst) -->
SOP-033 — Compliance checklist
SOP · owner: Legal & Compliance (Compliance Analyst). Layer: SOP/Runbook (
docs/canon.md). Procedure for building and maintaining status-tagged compliance checklists that track obligations to closure. Feeds the Legal Director’s register (SOP-032 (docs/sop/SOP-032-compliance-register.md)).
Interface Contract
- Inputs: obligation source (ADR / ToS / policy) ← from Legal Director · trigger: “audit requested”
- Outputs: compliance checklist + evidence → to Legal Director · trigger: “scan complete”
- Outputs: legal-opinion question + evidence → to Legal Director · trigger: “escalation requested”
- Handoff trigger (in): the Legal Director requests a checklist, or a new obligation (new ADR, ToS update, policy change) appears
- Handoff trigger (out): every in-scope obligation has a status (open / compliant / waived-with-reason), a cited source+date, and the file that will close it
- Definition of Done before handoff:
- [ ] Each obligation item carries status, severity, source citation + date
- [ ] Each open item names the owner and the file/migration that closes it
- [ ] Items needing a legal opinion routed to the Legal Director (
escalation requested), not answered - [ ] Checklist handed to the Legal Director; learnings captured if any
Trigger note.
audit requested,scan complete, andescalation requestedare registered verbatim phrases (Wave 1 additions, Operations-approved 2026-06-01) indocs/handoff-triggers.md. The producer/consumer phrasing is mirrored verbatim with SOP-031/032/034 so the register reconciles green.
Purpose
Turn obligations that live as prose (e.g. inside ADR-0017) into a tracked, citable checklist so the Legal Director and Principal can see, at a glance, what must be done, by whom, by when — and prove it.
When to use
On a Legal Director request (audit requested), when a new ADR/ToS/policy creates
obligations, or on periodic refresh. The richest current source is ADR-0017, which
holds ≥5 discrete open obligations with named owners but no checklist tracking them.
Flow
flowchart LR
A["Locate primary<br/>source (ADR/ToS/policy)"] --> B["Extract obligations"]
B --> C["Status + severity<br/>+ owner + closing file"]
C --> D{"Needs legal<br/>opinion?"}
D -->|yes| E["Route to Legal Director<br/>(escalation requested)"]
D -->|no| F["Record status"]
E --> G["Hand checklist<br/>→ Legal Director"]
F --> G
classDef s fill:#1d4ed8,color:#fff,stroke:#1e3a8a
classDef d fill:#0f766e,color:#fff,stroke:#134e4a
class A,B,C,E,F,G s
class D d
Text fallback: locate the primary source → extract each obligation → tag status, severity, owner, and the file that closes it → if an item needs interpretation, route it to the Legal Director with evidence; otherwise record its status → hand the completed checklist to the Legal Director.
Steps
- Locate the primary source (read the actual ADR/ToS/policy text — not a summary).
- Extract obligations: permitted uses, required actions, prohibited uses, expiry.
- Compare against current practice — is each obligation actually met? Cite the file that proves it, or mark open.
- Classify each item: status (open / compliant / waived-with-reason), severity (critical / moderate / low), owner, and the file/migration that closes it.
- Escalate any item needing a legal opinion to the Legal Director with evidence
attached (
escalation requested) — do not answer it yourself. - Hand the checklist to the Legal Director (
scan complete); capture learnings.
Roles / approvers
Authored and run by the Compliance Analyst; legal interpretation and severity calls by the Legal Director; closure evidence from the named owner (often Engineering).
Guardrails
- Cite sources + dates. Undated/unsourced items are flagged unverified.
- Label confidence: confirmed vs. inferred vs. unknown. No “probably fine.”
- No legal opinions — route them up (
.claude/agents/compliance-analyst.md). - No security-control or HR-policy edits — track whether, not author.
See also: SOP-032 (docs/sop/SOP-032-compliance-register.md) · charter (docs/units/legal-compliance/charter.md) ·
ADR-0017 (primary obligation source).