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Skilled Person Review of a Popular Mobile Payment Platform’s Financial Crime Controls

The Financial Conduct Authority (“FCA”) appointed FTI Consulting as the independent Skilled Person to assess the financial crime systems and controls of the UK entity of a peer-to-peer mobile payment platform. Operating under a Voluntary Requirement (“VREQ”), the firm needed to demonstrate that its controls were sufficiently robust. FTI Consulting’s assessment provided the FCA with an evidence-based view of the firm’s readiness to proceed, while also giving the firm a clear and regulator-aligned pathway to resolve deficiencies.

Our Impact

The review provided the client with a clear, evidence-based pathway to resolve the requirements of the VREQ.
The independent Skilled Person Review provided the FCA with an evidence-based assessment of the remediation required across the firm’s financial crime controls.
The report directly informed the FCA’s regulatory position, establishing that remediation of identified deficiencies was necessary.
The FCA gained independent assurance over the firm’s existing controls, control readiness, ability to reduce the risk of customer harm, and address unresolved financial crime control weaknesses.

Our Role

FTI Consulting independently assessed the firm’s financial crime systems and controls, leveraging operational financial crime remediation expertise to evaluate design adequacy and practical effectiveness against regulatory requirements.
The review placed particular emphasis on proportionality, recognising the client’s restricted operating status and the need for controls that were robust enough to manage residual financial crime risk without creating unnecessary barriers to customer offboarding.
FTI Consulting assessed the client’s core financial crime control framework, including customer identification and verification, risk management and rating, due diligence and enhanced due diligence, screening and single customer view capabilities.
FTI Consulting tested both design and operational effectiveness, including sample-based testing and targeted clarification sessions, to produce robust, factually grounded findings capable of supporting FCA decision-making.