Targeting

ICP & Account Playbooks

The accounts to call, the personas to ask for, the pains they carry, and the regulatory exposure that turns Shadow AI into a board-level conversation.

Best-fit accounts

Regulated industries, 250+ employees, an active Copilot / ChatGPT / Gemini rollout, and a named CISO, CCO, or CRO. Each card below maps the risk Shadow AI creates, the workflows where it shows up, the regulations that turn that risk into a finding, and the discovery questions to qualify the account in under 10 minutes.

Industry playbook

Wealth Management / Financial Advisors

What Shadow AI looks like here

Advisors paste client portfolios, KYC docs, and meeting notes into ChatGPT to draft client communications.

Why this is a board-level risk

Books of business contain PII, account numbers, and material non-public information. Leakage triggers SEC Reg S-P and FINRA 4511 violations.

Where AI shows up
  • Drafting client emails
  • Summarizing review meetings
  • Generating retirement projections
  • Researching securities
Regulations in play
SEC Reg S-P
FINRA 4511
FINRA 3110
GLBA

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"Most RIAs we talk to discover within 30 days that 40%+ of their advisors are already pasting client data into ChatGPT. How are you seeing it at your firm?"

Discovery questions to qualify the account
  1. 1.Has your CCO done an AI usage audit in the last 90 days?
  2. 2.What's your written policy on Copilot vs ChatGPT for client-facing work?
  3. 3.If a regulator asked for an AI inventory tomorrow, could you produce one?
  4. 4.How do you prove a client's PII didn't go into a public LLM?

Industry playbook

Banking

What Shadow AI looks like here

Branch and ops staff use ChatGPT to summarize loan files, customer complaints, and AML alerts.

Why this is a board-level risk

OCC, FDIC, and CFPB have all issued AI risk guidance. Third-party LLM use without governance is a Matter Requiring Attention waiting to happen.

Where AI shows up
  • Loan file summarization
  • Complaint response drafting
  • AML narrative writing
  • Vendor due diligence
Regulations in play
GLBA
OCC 2023-17
NYDFS Part 500
BSA/AML

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"Your peers are getting MRAs over AI usage in middle office. Have your examiners started asking about AI inventories yet?"

Discovery questions to qualify the account
  1. 1.How are you handling SR 11-7 model risk management for LLMs?
  2. 2.Do you have visibility into which AI tools your call center is using?
  3. 3.What's the plan for the OCC AI examination expected next cycle?

Industry playbook

Insurance

What Shadow AI looks like here

Underwriters and claims adjusters paste medical records, accident reports, and PHI into AI for faster decisions.

Why this is a board-level risk

HIPAA, state DOI rules, and NAIC Model Bulletin 2023-1 all apply. Carriers face both regulatory and class-action exposure.

Where AI shows up
  • Claims triage
  • Underwriting summaries
  • Subrogation research
  • Policy language drafting
Regulations in play
HIPAA
NAIC Model Bulletin 2023-1
State DOI

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"NAIC Model Bulletin requires you to govern AI used in underwriting decisions. How are you tracking what your underwriters actually use day to day?"

Discovery questions to qualify the account
  1. 1.Are you tracking AI usage by line of business?
  2. 2.How do you prove non-discrimination in AI-assisted decisions?
  3. 3.Who owns AI governance - IT, compliance, or the CUO?

Industry playbook

Healthcare

What Shadow AI looks like here

Clinicians and billing staff paste PHI into ChatGPT to draft notes, appeal denials, and summarize charts.

Why this is a board-level risk

Every paste is a potential HIPAA breach. OCR penalties can reach $1.9M per incident category.

Where AI shows up
  • Clinical note drafting
  • Prior auth appeals
  • Patient education
  • Coding assistance
Regulations in play
HIPAA
HITECH
42 CFR Part 2
State privacy laws

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"Your privacy officer is probably losing sleep over ambient scribes and ChatGPT. Are you governing those separately?"

Discovery questions to qualify the account
  1. 1.Do you have a BAA-covered AI option deployed?
  2. 2.How are you discovering shadow AI use across departments?
  3. 3.What happens when a clinician pastes a chart into ChatGPT today?

Industry playbook

Legal

What Shadow AI looks like here

Associates and paralegals use ChatGPT to summarize contracts, draft motions, and research cases - including privileged matters.

Why this is a board-level risk

ABA Formal Opinion 512 requires competent AI use. Privilege waiver from public LLM use is now a malpractice risk.

Where AI shows up
  • Contract review
  • Discovery summarization
  • Legal research
  • Brief drafting
Regulations in play
ABA Model Rules 1.1 / 1.6
ABA Formal Op 512
State bar guidance

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"ABA 512 says you need a defensible AI competence program. Most firms we see have a policy on paper but zero visibility in practice - sound familiar?"

Discovery questions to qualify the account
  1. 1.How are you preventing privilege waiver via public LLMs?
  2. 2.Which matters allow AI assistance and which don't?
  3. 3.Could you produce an AI usage log for a client audit?

Industry playbook

Pharma

What Shadow AI looks like here

R&D and medical affairs paste proprietary compound data, trial results, and patient narratives into AI tools.

Why this is a board-level risk

FDA 21 CFR Part 11, GxP, and trade-secret exposure. A leaked compound structure is irreversible IP loss.

Where AI shows up
  • Literature review
  • Trial protocol drafting
  • Medical writing
  • Regulatory submissions
Regulations in play
21 CFR Part 11
GxP
FDA AI/ML guidance

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"Pharma IP leakage to public LLMs is uninsurable. How is your CISO measuring it right now?"

Discovery questions to qualify the account
  1. 1.Do you have a sanctioned LLM for R&D?
  2. 2.How are you handling AI in GxP-validated systems?
  3. 3.What's your stance on Copilot in regulated workflows?

Industry playbook

Government Contractors

What Shadow AI looks like here

Cleared and uncleared staff use ChatGPT on documents that may contain CUI or ITAR-controlled data.

Why this is a board-level risk

CMMC 2.0, NIST 800-171, and OMB M-24-10 require AI inventory and risk management. A single CUI leak can suspend a contract.

Where AI shows up
  • Proposal writing
  • Technical documentation
  • Code generation
  • Briefing summaries
Regulations in play
CMMC 2.0
NIST 800-171
OMB M-24-10
ITAR / EAR

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"OMB M-24-10 mandates an AI use inventory. Are you ready for your next CMMC assessment to include AI controls?"

Discovery questions to qualify the account
  1. 1.Have you scoped AI within your SSP?
  2. 2.Which AI tools are FedRAMP-authorized for your environment?
  3. 3.How are you preventing CUI from reaching public LLMs?

Industry playbook

MSP / MSSP Partners

What Shadow AI looks like here

Your clients are all asking about Shadow AI - and you don't have a productized answer yet.

Why this is a board-level risk

Workforce AI Security is the next managed service. First-movers lock in 3-5 year MRR contracts.

Where AI shows up
  • AI risk assessments
  • Managed AI governance
  • AI policy as a service
  • Incident response for AI leaks
Regulations in play
Varies by client vertical

Each of these expects a documented AI inventory, a DPIA / risk assessment, and evidence that sensitive data did not reach an unsanctioned model.

Opener that lands

"Every one of your regulated clients is going to ask you about AI governance in the next 6 months. Do you have a SKU for it yet?"

Discovery questions to qualify the account
  1. 1.How many of your clients have asked about Copilot governance?
  2. 2.What's your current AI services revenue?
  3. 3.Do you want to white-label or co-sell?