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Lifting FCA Restrictions on an Electronic Money Institution

A UK subsidiary of a global electronic money institution entered into a Voluntary Requirement (“VREQ”) with the Financial Conduct Authority (“FCA”). The firm engaged FTI Consulting to design and deliver a remediation programme in response to a Skilled Persons Report, which had been commissioned by the regulator and had identified significant deficiencies and failures across the client’s governance, risk and compliance frameworks. The purpose of the programme was to leverage FTI Consulting’s expertise to enable the firm to address the report’s findings, manage the regulatory engagement and ultimately design, implement and embed robust frameworks that would allow the VREQ to be lifted.

Our Impact:

FTI Consulting enabled the client to develop robust governance, risk and compliance frameworks and embed them aligned to the firm's size, scale and nature of its business activities, delivering measurable and sustainable performance improvements across the organisation.
The client was able to demonstrate compliance with all relevant regulations and legislation, evidencing not only a targeted response to identified issues but a concrete shift to industry best practices.
The FCA lifted the VREQ, removing the operational restrictions placed on the firm and restoring its ability to operate and grow the business without regulatory limitation.

Our Role:

The firm’s governance and management oversight arrangements were restructured through the introduction of new board membership and committee structures, enhancing the target operating model across first and second lines of defence and clarifying firmwide roles and responsibilities.
FTI Consulting designed and implemented a new enterprise-wide risk management framework to include a comprehensive risk assessment, risk appetites and risk reporting, alongside a fully overhauled compliance framework covering new and revised policies and procedures across conduct, consumer duty, agents and distributors, complaints, conflicts of interest and compliance monitoring.
FTI Consulting transformed the firm's financial crime systems and controls across all areas of the anti-money laundering (“AML”) and counter-terrorism financing (“CTF”) control framework, including onboarding, transaction monitoring, screening, sanctions, fraud monitoring and anti-bribery and corruption.
The implementation of an outsourcing framework resulted in the exit of underperforming outsourced functions and a redesign the firm's safeguarding framework, capital adequacy and liquidity policies and procedures.