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Case Studies

A few examples of our recent work and what our clients had to say about us.

3Lod & Then Some

The Brief – After an internal strategic review and external PRA examination, it became clear to our client that their operational risk management framework was flawed in a range of areas. With ambitious plans to re-engineer their whole framework and underlying system, our client counted on us to provide their far-reaching goals.

The Solution We were asked to undertake a number of key design and implementation roles within their transformation programme. As the driving force behind significant workstreams and projects, our team led the rollout of Three Lines of Defence model across the organisation which quickly came to be the catalyst and cornerstone for behavioural change.

Central in developing a number of components of the new framework, including creating the client’s first ever bank-wide control library and the team were also essential in leading the execution of a bank-wide risk assessment refresh, including taking responsibility for all follow-on training and education globally.

The Results – The client met every one of their regulatory commitments on schedule, including the release of their new framework, system and risk assessment recharge. The method which the team delivered this challenging programme has set a new bar for best practice within the bank and the client is delighted with the commitment, expertise and delivery skill the team has demonstrated.

Procedures & Best Practice

The client, a small IFA network had a number of Defined Benefit Pension Transfer cases that they had transacted. As part of their annual checks, they needed help in checking a number of high-risk cases and an analysis of their procedures, to ensure best practice.

We engaged our Pension Specialist who worked onsite and remotely, creating a report that was accepted by the senior management, including several recommendation (some of which they had implemented immediately) to provide a better and more compliant service.

Another tick in the box.

General Insurance Challenge

An insurance distributor had fallen behind with their Insurance Distribution Directive (IDD) project due to a rapid turnover of non-committed staff as well as numerous demands from their underwriters. Existing issues were complex due to multi-channel distribution through ARs and IARs. Customer journey’s were not identified and mapped, documentation was not prepared and there was minimal knowledge of the changes needed for the customer journey as a whole.

We set to identifying the entire distribution channel from brands through to individual products at this multi-million pound turnover business and identified numerous errors, inconsistencies and anomalies. A 6-week project turned out to be 8 weeks (mainly due to time taken in unearthing secrets) with some small areas remaining outstanding (but in hand) when we wrapped up the project.

Several projects were born off of the back of our work but the ultimate commitment to a risk framework was “to be managed internally” – this usually means that nothing will be done as the tone from the top was weak and incoherent. Strategically there were many issues that any risk-framework, would only have exacerbated at this time. We withdrew respectfully. You can’t win them all.

Onboarding and more

AML/CTF/KYC Project with a foreign based Bank UK Branch. The client needed a full review of AML & CTF issues including on-boarding and review all financial crime governance. Existing issues were due to legacy compounding of poor document management and a “control” compliance regime. Cases were back-logged for approval and getting worse. Identifying the three main business areas and creating a workable document for all departments, creating new procedures that encompassed all forms and reports used we created a new suite of governance that had the buy in from business, through to the CEO.

There was no budget for new software, so we updated the AML/CTF governance and created a KYC onboarding procedure that worked with existing systems. New controls were put in place and revised KYC assessment were implemented, fulfilling the client’s need and including all training and desktop process mapping to complete the governance suite.

Review and Update Governance

AML Project with a foreign based Investment Bank UK Branch, following several S166’s. The client needed us to review and update the AML/CTF governance and create a KYC onboarding procedure that worked with existing systems. New controls and KYC assessment were implemented, fulfilling the client’s need and including all training and process mapping to complete the governance suite. New revisions approved and problem solved

Disclosure and Suitability

Retail Financial Services firm that was in the process of a retirement buyout/handover. Several issues around file completion and KYC, suitability reports and appropriate advice. FCA visit had shown other issues in disclosure and suitability. Engaged to provide support service to the new and existing management/owners any challenge was met with sulking and communication blackouts. After FCA letter suggesting file checks were carried out, the new management watered down their interpretation of the requirements and when we recommended a PBR, the client rejected our recommendation and we discontinued support package with appropriate notice. Post our departure – Client entered into enforcement until cases are reviewed and remediated.

Preparing and Assisting

Compliance Consultant was tasked with preparing and assisting a predominantly non-financial services BOD to prepare and make a banking application. This was to include all governance, risk management, compliance monitoring and reporting, TORs, ICAAP, ILAA, software selection, IT platform and BCP preparation.

Once the project plan was agreed the process would then take them through Option B to permissions being granted, then on to launch. There was an existing CCA function providing local business loans as well as mortgages through the Housing Act provisions for local authorities, and these were to migrate to the bank as and when the mobilisation phase was reached.

Specialist consultants were deployed to create the necessary areas for development of the business plan and co-ordinate the elements into a full application.

The Compliance Officer for a large EU owned insurance group required a review of the firms’ UK Conduct Risk Framework. The Framework has been in existence for several years and the firm wanted independent assurance that it was still fit for purpose or advice on possible enhancements.

We undertook a full review of the Board approved compliance suite of policies relevant to Conduct Risk and the Framework document itself reviewing design, operation, efficiency and effectiveness;

Key individuals’ within the firm were interviewed to assess their view of the effectiveness and efficiency of the framework and its’ output.

A report was prepared within the timeframe requested for upward reporting through the governance structure.

The Board of Directors was satisfied that the firm was meeting regulatory expectations for conduct risk and had oversight of recommended enhancements.

Another happy conclusion from the effective review of governance and subsequent testing.

The client was being restricted by the regulator as they were unconvinced that the firm was conducting their risk assessment and mitigation effectively. A review was required to assess whether the client’s financial governance and operational framework was fit for purpose and aligned with the Financial Conduct Authority (FCA) regulatory requirements to register and operate as a crypto asset firm in the UK. This called for a maturity assessment to depict the current state of a firm’s controls and their level of regulatory compliance. It also benchmarks and tests against a firm’s existing standards, global standards, and most importantly, against regulatory expectations.

We reviewed the governance framework of the firm to determine if the policies were applied correctly in the operational environment and made recommendations, based on identified gaps, for uplifts and updates to the existing policies. One of the main recommendations that emerged included the implementation of global standards by which the UK and European policies are based on the documents produced at a group level and tailored to meet the local UK requirements while still meeting the global minimum standards.

We provided the client with a detailed report that contained the findings of the thorough review. They conducted a gap analysis against the firm’s current approach to AML and current regulatory requirements which allowed the firm to gain a detailed and independent understanding of its AML governance framework and FCA requirements to continue to operate in the UK.

The regulator approved the changes and restrictions were lifted.

Under review – please come back soon!

The global investment bank had taken over a foreign based stockbroker and identified that they had not conducted Disclosure & Transparency Reporting correctly, when they tried to incorporate the stockbroker details. Additionally, the company had been censured for breaching the Panel for Takeovers and Mergers rules on several occasions.

We were asked to design, build and implement an IT solution to capture worldwide holdings as close to real time as possible.

We spent several months with the bank staff, interpreting the rules, creating and testing and finally deploying the software which effectively had twin core analysis due to the disparity between the two suite of reporting requirements.

The system completed the regulatory requirements and was the first of its type in the city.

An EU bank with a major research facility based in the UK wanted a more direct approach for the foreign based SMFs to be trained, and the local Certificated Persons, to have effective and meaningful, ongoing training.

At Compliance COnsultant we have a range of solutions from the basic introduction to financial services to Conflicts of Interest Workshop training and were happy to oblige.

Training design takes time but we managed to compile a suite of solutions for both levels of staff, including a test paper. We delivered the training and tests, and the Bank requested that the follow ups were to be done with the Line Managers.

Thought, application, completed!

Under review – please come back soon!

One such success story is that of ABC Bank, a prominent FCA authorised firm.

With the advent of Consumer Duty and under the leadership of their fairly new and dedicated compliance officer, ABC Bank wanted to navigate complex regulatory requirements while maintaining a strong focus on customer service.

We assisted with the review of governance and processes and worked from the bottom up, as well as strategically and obtained a positive result.

By implementing robust compliance controls and fostering a culture of compliance throughout the organisation, ABC Bank not only met regulatory requirements but exceeded them. As a result, the firm gained a reputation for trustworthiness and reliability, attracting a growing number of clients.

Another inspiring example is XYZ Insurance, an FCA authorised firm specialising in providing insurance solutions to individuals and businesses. Facing stringent regulations in the insurance industry, XYZ Insurance recognized the need for a proactive approach to compliance.

Their compliance officer took the initiative to develop a comprehensive compliance program, review of processes and identified vital controls that addressed key regulatory concerns, including data protection and anti-money laundering. Once these controls were evaluated and with some repositioning and tweaking, their objectives were met and the whole process was streamlined.

By doing so, XYZ Insurance not only ensured compliance but also gained a competitive edge over their rivals. The firm’s commitment to compliance led to increased trust from clients, resulting in a substantial growth in customer base and revenue.

IDD was being introduced into the General Insurance market and the firm concerned had done little in preparation.

Compliance Consultant was called upon to assist.

Having identified the automated processes that would fail the new rules, it was established that an IT change request would take several months to effect. The business could not afford to shut down for this time, so we reviewed the actual rules.

The regulators rules are often grey and fuzzy, allowing an interpretation. Good compliance is not about what you do, it is what you write down you did and why. On identifying the key requirement being “on conclusion of the start  of the contract” we formally changed the firm’s interpretation to mean before the 14 day cooling off period, temporarily until the IT fix was in place.

As a result of a huge Section 166, Skilled Person’s Report, a large broker dealer had the requirement as part of the Risk Mitigation Plan to ensure that the risk department was functioning effectively.

On analysis we discovered that the risk framework was too granular and additionally there was no collation of the risks reported, due to the reporting being free-type. No keyword analysis was performed and several risks of the same type lay undetected.

We rewrote the global risk framework and introduced category and risk based reporting to the entire organisation whereby the various legal entities could provide risk reporting and management at a local and global level.

Another tick in the box!

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FCA/PRA
AUTHORISATIONS

Too many regulatory compliance consultancies provide a range of stock or off the shelf services, but we are leading FCA compliance & authorisation consultants and provide bespoke services at a high standard.

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COMPLIANCE BENCHMARK
AUDIT & PROJECTS

We assess, compare, test, evaluate and score your compliance systems and controls against best practice and the latest regulations. We check your Governance from Terms of Business  through to Outsourcing polices.

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TRAINING
SOLUTIONS

We have an impressive array of training courses available covering a number of subjects and implementations (such as SMCR) and will amend/alter and update each course to be specific for you.

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CALL US TODAY ON 0800 689 0190

We offer you a simple fixed fee…
…once we have a good idea of your business complexity.

Gerry Neu
Gerry Neu
2023-06-15
Trustindex verifies that the original source of the review is Google.
Lee, in particular, but the whole team has excellent FCA experience and provide the context for solid advice. What stands out, especially, is the practical approach and the understanding of compliance within a commercial environment. Much appreciated assistance in an FCA application, but also policies and procedures and MLRO activity.
SRUTI SOURAV SARANGI
SRUTI SOURAV SARANGI
2023-02-21
Trustindex verifies that the original source of the review is Google.
Compliance Consultant had imparted two days intense training on key compliance subjects . With highly experienced trainer, excellent content and captivating sessions they delivered the best to our team. We are thankful to Compliance Consultant for their services.
Simon Dhillon
Simon Dhillon
2022-08-23
Trustindex verifies that the original source of the review is Google.
I worked with Compliance Consultant for 2 years and was involved in a variety of projects for various firms, both start-ups and established. Lee was a pleasure to work with and was very knowledgeable about all aspects of compliance, this provided reassurance that client work was carried out to a high standard. The team at Compliance Consultant worked very closely and was always on hand to provide assistance or advice on specialist areas for eg FCA Authorisations or Audits.
SMTAKS
SMTAKS
2022-08-15
Trustindex verifies that the original source of the review is Google.
In a high pressure situation, Compliance Consultant stepped in to help us further understand the requirements and completely changed the authorization documentation urgently needed.
Angela Young
Angela Young
2022-01-27
Trustindex verifies that the original source of the review is Google.
First class service in every way. Whilst applying for FCA authorisation the original compliance company we were working with let us down. Feeling despondent, Lee from Compliance Consultant stepped in and assured us we would have our application submitted on time. Suzanna was our direct contact and she worked tirelessly to ensure we met our deadline. Not only did we meet our deadline, but our completed application was submitted to the FCA, 1 week ahead of schedule. Both Lee and Suzanna took the time to communicate clearly the detail within each section of the application. They went above and beyond and felt more like friends by the end of the process. I would highly recommend Compliance Consultant both in terms of professionalism and value for money. We look forward to working with Compliance Consultant in the future.
Grant Townshend
Grant Townshend
2022-01-10
Trustindex verifies that the original source of the review is Google.
We approached Lee between Christmas & New Year about some compliance work we urgently needed completing for a newco setup. He communicated very clearly what we would need and why. Once instructed, he delivered this on time and cost effectively. Recommended.
Mohamed Yassin
Mohamed Yassin
2021-10-28
Trustindex verifies that the original source of the review is Google.
Outstanding job on every level. We are very pleased with their work. Done on time, done on budget and they know what they are doing. They handled everything with extreme professionalism and delivered our project in a timely manner. We couldn't be happier with the end outcomes, Lee and his team were extremely thorough, understanding and responsive throughout each stage of our contract. We look forward to working with them in the future on our project. Thank you, Lee and Compliance Consultant team.

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