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.
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.
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.
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.