Case Study Drop Downs

Operational Risk Framework
businessman_silhouette_basic_150173Lod & 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.

IFA Pension Transfer Checks
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.

Insurance IDD Woes
businessman_silhouette_basic_15017General 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.
Foreign Bank AML/CTF Needs
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.

Bank S166 Pain
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
Retail Channel With Issues
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.
Bank Start-Up For a Local Authority
businessman_silhouette_basic_15017Compliance 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.

Senior Management Regime Implementation of Project Plan

businesswoman_silhouette_carry_file_15038Compliance Consultant was asked to perform a gap analysis and project plan creation of a small financial operation including a bank.

The previous incumbent had left an array of notes but the dates and sequence were often missing. Our task was to collate, assess, analyse, apply to latest SMR requirements and identify the documents needed to be reviewed and updated. There were several external stakeholders including two sets of legal firms.

We created a workable and pragmatic action plan and identified the key steps, recording them on a project plan with milestones and phases differentiated for implementation. The project plan was created to include the whole implementation phase until March 2017.

Conduct Risk Framework Implementation
businessman_silouette_tie_3091A UK Building Society had stumbled across challenges when implementing a change project of Conduct Risk Framework implementation, having let the previous consultant go. Assessing and working with the existing Risk Framework provided us with an opportunity to deliver a number of Conduct Risk propositions, as well as discussions with senior management and divisional heads regarding the changes required. Through that work we have also conducted webinars and even published a book.

Risk Management

icaplogobusinessman_silhouette_basic_15017For ICAP plc (an Inter-Dealer Broker) Compliance Consultant (Formerly CEI Compliance) were tasked with reviewing and defining a new risk framework, loss reporting and streamlined, cohesive linked system to manage their risk exposure.

Here we identified misapplied rules and inaccurate ratings applied to the risk process. We identified time wasting elements and log-jams as well as disconnects and dead ends of the current system.

By re-engineering the process and creating a relevant and pertinent taxonomy, with risk identification along the lines of industry best-practice but specially formulated to identify the uniqueness of the client’s operations, we provided a range of solutions and options to assist in Risk Management and production of their annual ICAAP document, resulting in significant savings to their regulatory capital requirement.


Suitability - IFA Client Bank Purchase
businesswoman_silhouette_carry_file_15038With a large Independent Financial Adviser (IFA) requiring assessment and appraisal of a sample of client files purchased from another IFA before final payment was made.

It was soon evident that there was a need for an overall review of each and every sale as there was poor documentation and minimal suitability evidenced in any of the files. In a short time we assembled a group of specialist reviewers and completed the work within 3 weeks.

The final result was a fully compliant suitability appraisal of some very poor files and documented evidence that there was no duty of care demonstrated to even a “Treating Customers Fairly” standard.

Systems Design - Investment Bank
businessman_silouette_tie_3091Working with Standard Bank, a South African Investment Bank we analysed and interpreted the requirements under the Disclosure and Transparency Reporting (DTR) and the Panel for Takeovers and Mergers (POTAM).

The intention was to create as near as possible real time web based depositary from all the entities worldwide to provide the global position of all UK and dual listed securities.

Following on from this work the system was then expanded and we advised the inclusion of all global equities with the application of the data provided to the Research Department in Johannesburg to be able to have up-to-date positions so that they could declare any conflict of interest on any research material, a requirement by multiple jurisdictions around the world.


Course Design

businesswoman_silhouette_carry_file_15038As part of the brief for the Zurich Banking Group, there was a need for an Operational Risk Framework to be rolled out worldwide. Originating from Switzerland this had been delayed for some time due to staff issues.

The banking group, unlike the global insurer, spanned four jurisdictions and each had separate processes that need to be identified, recorded (with primary and secondary controls identified throughout) and uploaded into the global main risk database in specific formats.
We coached and assisted the various process owners in the recording of the processes and facilitated further course design. Additionally, the reporting tool (SWORD) application needed implementation including training of all staff. Launch was co-ordinated to ensure required collation of all losses, near misses and breaches were fully registered, escalated and approved as appropriate.

Retrospective TCF checks
businessman_silhouette_basic_15017Working with another consultancy and Exeter Friendly Society, the initial brief was to review previous years complaints to ensure that the decisions reached and the responses provided were transparent, clear and fair as well as congruent and consistent with the business decisions at the time.

These assessments were also checked against contemporary Treating Customers Fairly practice and the standards applied retrospectively, ensuring that the customers had a fair deal and that no one was given a bad customer experience.

And so much more ….