Multi-disciplinary reasonable assurance review of high volume fintech dealing with business and personal customers
Our payments client had a legacy of 180 recommendations from gaps identified in prior Skilled Person reviews on which the FCA required assurance. As the origin of a number of these recommendations was an ‘Anniversary Real-Time Gross Settlement’ (RTGS) review the scope included: Governance; Risk management; Safeguarding; AML and CTF; Onboarding Due Diligence; Business Continuity Planning and Consumer Duty.
In addition the FCA was looking to gain awareness on the Firms progress with respect to implementation programmes on APP Fraud and Consumer Duty.
The Firm was subject to a VREQ on onboarding and had been through a programme of restructuring including changes in all key stakeholders, systems and processes.
We mobilised a multi-disciplinary team to ensure there was an appropriate subject matter expertise and experience in place to address all specific areas of regulatory concern. As the Firms remediation programme for a number of the original recommendations was still underway at the point of commencement of our engagement we worked with the Firm and the FCA to deliver a two phase Skilled Person review that covered all aspects and the high volume of historical recommendations.
Given our review involved the assessment of Design and Operational Effectiveness of the changes the Firm was implementing, this required ongoing engagement with the Firms project team and regular discussions with the Senior Leadership Team (including the Board).
The project was sequenced to allow priority recommendations to be reviewed earlier and to be flexible enough to respond quickly where the FCA asked us to hone in on certain aspects at short notice. We managed the programme so the level of activity could ebb and flow – for example where we were waiting for new clients to be onboarded. This meant the client was only paying for time where our team was actively engaged on the project.
We delivered reports for each phase that addressed the multiple review standards expected by the FCA on the assignment including Review and Recommend, Limited Assurance and Reasonable Assurance.
An outcome of the first Phase was that the FCA was comfortable enough to vary the terms of the VREQ meaning that the Firm could recommence onboarding at all Risk Levels (Low, Medium and High) working within certain parameters.
An outcome of the second Phase was that 3 years of reviews and hundreds of historical recommendations were evaluated and rationalised into only the key areas of remaining. This left the Firm with a much reduced and fit for purpose remediation plan.
Throughout the project we provided appropriate challenges and good practice observations so the Firm could enhance their programme ensuring its sustainability.
