Who we help
We help a broad variety of sectors. Whilst the regulatory rules and guidance are often similar, the way you have to interpret them will differ. Below we have set out a selection of firms we have experience helping:
Banks (commercial, investment, private and retail)
Asset Managers
Payment firms (APIs)
Fintechs
Electronic Money Institutions (EMIs)
Funeral planners
Intermediaries
Credit brokers
Lenders
Lawyers
Brokers
Wealth Managers and Independent Financial Advisors (IFAs)
Private equity houses
Hedge funds
Insurance firms
Trading houses
Exchanges
Gambling firms
Real estate firms
Auction houses and dealers in high value goods
Art market participants
We have also done extensive work supporting governments, regulators and policy makers.
If you would like to speak to any of our clients about what it is like working with us in these sectors we would love to introduce you to them.
Why you need us
All of our clients are different, so we wouldn't like to guess your reason for contacting us - but we know what most of our clients ask for help with.
Our range of services is extensive, but generally we find firms are either looking for something proactive, or being forced to react to a situation. Specific reasons for engaging us typically include:
Independent reviews:
Maybe you want a health check for your own comfort, or maybe the regulator has required you to have one (e.g. skilled person review / section 166, Court appointed Monitor). Once we agree the purpose of the review we can give you assurance over the systems and controls you have in place
Regulatory response:
The way you interact with a Regulator has a huge impact on the period of time you are likely to be of direct interest to them. Providing your Regulator with confidence that you are on top of regulatory issues, and that your plans to address identified problems are both sensible and realistic will allow you to remain in control of remedial work. We are experts in helping firms with regulatory responses.
Risk appetite and risk assessments:
As the bedrock of your risk based approach you need solutions which are comprehensive but without becoming unwieldy. If your risk framework doesn't help you understand the controls you need, it isn't fulfilling its purpose. Compliance and financial crime risk assessments are the foundation of how we help you.
Policies, procedures and control enhancements:
Regulations and regulatory expectations change over time. You might want us to develop new controls for you, or review and enhance the ones you have. We commonly see firms persisting with historic policies and procedures without challenging the purpose. Everything you put in place needs a clear purpose and our review of your policies and procedures will look to drive better outcomes in a smarter way
Operating model and organisational design:
Sometimes you need that external perspective to step back and look at how you're doing things to help identify a better, smarter, more efficient approach. We focus on purpose in order to challenge the status quo
Training:
People can only be expected to do the right thing if they understand what that is and why it is important. Training has to lead to your staff actually thinking or doing something differently. We design all of our training with this in mind
Technology:
Whether its an expensive strategic system or a tactical solution, you need to know your technology is achieving its purpose. You also need to know whether it could do it better. We can support the selection, definition, configuration and testing of your systems
Expert witness:
If you're facing litigation, you're going to need people who not only understand the rules inside out, but also know what they mean in practice. It's our practical experience and focus on purpose which sets us apart
FCA Authorisations / applications / registrations and variations of permissions:
If you're looking to carry out regulated activity, you'll need to be appropriately authorised / registered with the relevant regulators. You might need help getting your framework in place, or navigating the process
What’s the subject matter
Our services broadly split into four groups:
Governance and culture:
Governance and culture are often identified as the root cause of regulatory issues. Conversely good governance and a positive compliance culture can make a firm not only regulatory compliant, but also more commercially successful.
Financial crime compliance:
Financial crime remains a high priority for regulators all over the world. Money laundering, terrorist financing, economic sanctions, bribery, tax evasion and market abuse pose daily challenges to regulated firms as well as the sound functioning of markets.
Recent focus areas from our clients have been KYC / CDD / EDD procedures; financial crime risk assessments; anti-bribery and corruption frameworks; trade based money laundering; and transaction monitoring / payment screening system reviews.
Risk Management and controls:
One size does not fit all. The size and scale of the risk framework should be proportionate to the business model considering the size, scale and nature of activities. Recent areas of focus from our clients have been on the identification and mitigation of risks; the development of risk appetite statements; thresholds; and reporting mechanisms (including MI). Controls are a fundamental element of risk management, and their effectiveness is key to reducing risks, we have worked with firms to ensure models are appropriately risk based to deliver fair outcomes for customers and operational resilience.
Conduct and compliance:
Fair treatment of customers is essential. Our work with firms includes compliance support at each stage of the retail product lifecycle; from design and distribution of financial products, pricing, marketing and advertising, customer communications, quality of advice, sales practices, management of conflicts of interest, complaints handling, conduct of business rules and guidance, collections and arrears management, pre- and post-sale service and retail conduct risks associated with each of these stages. We pride ourselves on our proportionate approach and understand that smaller regulated firms have different needs.
ESG and sustainability
All companies are being impacted by the drive to be more sustainable, whether in their own business practices, in oversight of outsourced operations and supply chains, or in their guardianship of assets. The legislative landscape in this space has evolved exponentially and continues to do so as more regulators take action to drive change to a greener, cleaner future.
Whether getting to grips with new disclosure requirements, seeking assurance on compliance with local or overseas regulatory obligations, or ensuring effective governance and oversight of corporate sustainability initiatives, we can help.
Where you are
We're based in London, but we work globally.
The pandemic of 2020 has proven that remote working can be effective, so our physical location will never be a barrier to working with you. We know sometimes things are just easier face to face though, so we're ready to travel if needed.
And although the specifics of regulation might vary country to country, the principles are generally the same. This is where our focus on purpose and outcomes really sets us apart from the crowd. Of course we'll make sure the specific details are covered, but we're highly confident in our ability to adapt to local requirements to keep you compliant.
In recent years our team have worked on site, to local regulations, in the UK, Ireland, USA, Norway, Mexico, Brazil, Uruguay, Hong Kong, Philippines, Singapore, Australia, Taiwan, Malaysia, Cayman Islands, Barbados and UAE.
When in your lifecycle
We'll be here when you need us, wherever you are in your lifecycle:
New business: you need all of the right pieces in place
Aggressive growth: there's a lot of change and you need to remain compliant
Maturity and sustainability: you need to reduce cost or simplify your processes
When you need assurance: you're looking for peace of mind
When you identify an issue: something needs fixing
Under regulatory scrutiny: you need help navigating a situation
If you have to wind up: you want an orderly and controlled exit
How we can structure it
There are four simple options for how you can engage us:
Projects:
Most of our work is project based. We'll agree the outputs / outcomes you're looking for, scope, approach, team and the price up front with you. We work methodically and focus on our communication with you.
Secondments:
If you need resource on a longer term basis, or to support with a range of non-defined tasks, a secondment may be appropriate. Our highly experienced and capable staff will work under your direction for a defined period of time.
Ad-hoc advice:
Many clients find it reassuring just to have us at the end of the phone. Our ad-hoc arrangements mean we've got an agreement in place so we're here when you need us, whether you want to run an idea by us, check your interpretation of something, or need a specific answer.
Referrals:
If for whatever reason we're unable to help you right now, we will tell you. We maintain an extensive network of highly respected consultants who we can refer you to on a no obligations basis.