Regulatory Remediation & Business Model Overhaul for a Global Payments Firm

Project Objectives

The client had suffered a suspension of their regulatory licence, and needed a partner to help them put right the financial crime systems and controls deficiencies so that they could pass muster with the FCA, restore their licence to trade, and get back to business.This involved a reworking of the business model, including systems and controls, and a large remediation programme.

Project Execution

The specific challenges that the client was facing into centred on ensuring that they could understand what the FCA was seeking for them to do, update various fundamental components of the business model (governance, MI, financial crime systems and controls, capital adequacy) to achieve compliance under a significant Section 166 review, and be cleared to operate normally with their customer base again. The client did not have the relevant SME expertise in house, nor did they have the breadth of resources to undertake the remediation, and Brighter was able to provide that in-depth capability for the client at pace, with the right skills and approach needed, and help them work through the various requirements that they needed to complete.

The financial crime area continues to evolve at pace, and the client chose to deploy our expertise in the timeframe required to meet regulatory expectations, including the design and specification for the Transaction Monitoring capability, and then back fill with internal resources over time with knowledge transfer occurring from the Brighter SME’s to internal teams.

Solution

Brighter was able to provide that in-depth capability for the client at pace, with the right skills and approach needed. Brighter provided leadership to support the board, programme and project managers, insight and reporting, and multiple teams across the programmes of work, across the broadest range of financial crime requirements. This included KYC, at both CDD and EDD levels, transaction monitoring, SAR’s, updating policies, procedures, processes, implementing systems for all of the aforementioned (design, testing, implementation), and a full bore remediation programme for its client base. Brighter supplied up to 60 people for around 22 months, replacing Deloitte who had failed to make appropriate progress in their previous 5 month tenure. This was a significant project, where the founders worked very closely with the client CEO and COO to ensure that all aspects of the service were delivered effectively, on time, and within budget.

Approach

Brighter deployed its most senior leadership team, and some of its most experienced Associates, to provide the client with the specialist SME’s with the right knowledge, experience and capability to lead the client requirements in respect of its Section 166 review work. Brighter worked collaboratively with the client, and the skilled person, to ensure that all objectives were met, reporting was clear, that the Regulator was appropriately appraised of progress, and that the client could demonstrate achievement of the requirements.

Outcomes

Quantitative
The client achieved a successful Section 166 assessment, having its licence restored by the FCA in December 2021, having deployed a robust reworking of its core business operating
model, a successful remediation programme, and updated systems and controls for its financial crime requirements.

Brighter were able to complete the project work for circa £5.2 million, as compared to the competitor pricing which we understood was in the range of between £9 and £12 million. Brighter were able to help the client implement multi-lingual teams to ensure remediation for its diverse customer base.

Qualitative
Brighter provided regulatory certainty for the client in its dealings with the skilled person and the FCA. Brighter’s input was welcomed by the skilled person and was a decisive factor in the
regulator being able to restore the client’s operating licence.