Case Studies

Board-grade challenges, delivered.

 

Snapshot Summary

Client: Wealth & Mortgage Broking Network.

Engagement: Lead the disposal of group businesses and wind-down remaining entities.

Outcome

Saleable group entities exited, releasing value, protecting jobs, with minimal disruption / publicity.

Progressive downsizing of the group undertaken.

Data preparation and case review solution for a redress exercise completed.

Remaining group entities placed into administration / liquidation and redress case data handed to FSCS.

The Challenge

A national wealth and mortgage broking network faced significant strategic headwinds and sought to undertake a strategic review to determine the options available to the shareholders.

The review surfaced a series of opportunities and challenges in arresting performance and setting the group up for future success.

Following the Boards decision to execute a controlled sale and closure of the group, we were tasked with delivering the business resolution.

Our Approach

In a challenging and rapidly changing environment, our approach encompassed:

Rapidly mobilised a programme and necessary controls to transfer corporate assets and people out of the Group, and review high risk products in order to enable an orderly wind-down and de-authorisation.

Engaged, informed and aligned stakeholders around a common plan and approach.

Restructured Executive Team to ensure appropriate leadership and behaviours needed to support the journey.

Directed M&A activities, data room creation, transitional service negotiations and execution, migration activities and communications.

Drove activities to eliminate waste, optimise value and downsize progressively.

Quantified historic liabilities, determined populations and extracted data to support redress.

Directed key advisers, insolvency practitioners, legal advisers and M&A specialists.

The Results

Safely transitioned group entities to new owners and supported transitional services.

Protected customer service and avoided significant disruption in the sale and closure process.

Optimised value for shareholders within the constraints the Board agreed.

Secured over 100 roles through transition to new ownership.

Avoided adverse publicity for significant national brands.

Established historic liability, identified customers, prepared data for a redress programme.

Snapshot Summary

Client: Mid-tier UK Bank.

Engagement: Redesign and deployment of regulatory remediation programme.

Provision Managed: £0.5 billion.

Outcome

Avoided an FCA s166 review.

Significantly reduced financial penalties.

Transformed regulatory relationship from strained to collaborative.

The Challenge

A major UK bank faced imminent regulatory enforcement. The Financial Conduct Authority (FCA) had signalled serious concerns over the handling of a customer remediation programme. The previous consultancy (a Big Four firm) had failed to develop an acceptable strategy or operating model, and critical regulatory correspondence had been left unanswered for over four months.

Internally, the bank lacked the specialised capability and confidence to course-correct, and the prospect of a Section 166 (skilled person review) and substantial financial penalties was becoming unavoidable.

Our Approach

We acted with urgency. Within days, we led a comprehensive diagnostic to assess the current state and regulatory concerns. Drawing on deep regulatory insight, we:

Designed a robust remediation strategy and operating model, with a 30-day tactical plan and longer-term roadmap, which were formally endorsed by the Executive Committee.

Re-engaged the FCA proactively, presenting our strategy face-to-face to demonstrate decisive leadership and credibility.

Drafted key regulatory artefacts, including policies, control standards and high-level processes, ensuring full alignment with FCA expectations.

Validated redress decisioning logic with both the FCA and the Financial Ombudsman Service (FOS), mitigating the risk of downstream disputes or appeals.

Established and oversaw a scalable remediation operation, including live incident management and exception handling through to warranty exit.

Embedded knowledge transfer, leveraging internal teams to ensure sustainable capability and a controlled, low-risk disengagement.

The Results

The intervention delivered immediate regulatory confidence, effectively neutralising the threat of a s166 review. The bank not only avoided additional enforcement measures but achieved a material reduction in financial penalties.

Most significantly, the regulator’s stance shifted from adversarial to constructive — a turning point in the bank’s regulatory journey. What had been a failing programme became a model of good practice, built on clarity, competence, and credibility.

Snapshot Summary

Client: Challenger UK Bank.

Engagement: Design, deployment and operation of a regulatory remediation programme.

Provision Managed: £110 million.

Outcome

Avoided an FCA Section 166 review.

Remained open to new business.

Reduced forecast remediation and redress costs by £40 million (36%).

The Challenge

A UK challenger bank faced the threat of imminent enforcement action following serious concerns raised by the Financial Conduct Authority (FCA). Failings had been identified in its systems and controls, particularly relating to customer charging and the handling of fraud.

The firm had recently undergone acquisition, and the new ownership had secured a short window from the FCA to present a credible strategy and plan for remediation — covering operational deficiencies, control frameworks, and redress for affected customers.

We were engaged within this critical timeframe to design the strategy, agree the remediation plan with the FCA, and deliver the programme at pace.

Our Approach

Acting swiftly, we initiated a full-spectrum diagnostic to assess the current control environment and regulatory gaps. Leveraging deep regulatory experience, we:

Designed a robust remediation strategy and operating model, supported by a detailed short term tactical plan and longer-term roadmap, endorsed by the Executive Committee.

Re-engaged the FCA directly, presenting the plan face-to-face to establish confidence and secure alignment at the outset.

Mobilised the programme rapidly, implementing clear governance, accountabilities and resourcing across multiple workstreams.

Conducted a pan-business diagnostic, covering all customer-facing processes and both compliance and legal obligations.

Built a fully costed remediation model, actively challenging internal risk appetite and legal opinion to reduce programme costs while satisfying both regulatory and board expectations.

Managed delivery to conclusion, embedding a fit-for-purpose operating model, addressing all key failings (or formally accepting residual risk), ensuring customer redress, and transitioning the regulatory relationship from intensive oversight to standard supervisory engagement.

The Results

The bank successfully avoided formal enforcement action and retained the ability to onboard new business throughout the programme — a critical commercial priority.

Our strategic and operational intervention led to a 36% reduction in projected remediation and redress costs, equating to £40 million in financial savings.

Importantly, the regulator’s stance shifted from highly engaged to supervisory norm, reflecting restored confidence in the firm’s leadership and operational resilience.

Summary Snapshot

Client: UK Bank.

Engagement: Diagnose root causes of accelerating fraud losses, design and deploy effective controls to arrest performance decline, and support the internal fraud team through a high-pressure period.

Loss Deterioration: Forecasted at up to 4x annual run rate.

Outcome

Root causes identified and resolved.

Fraud losses returned to within tolerance levels within 6 months.

Team stabilised and platform for sustainable performance established.

The Challenge

A UK challenger bank faced a sharp and unexplained rise in fraud losses. Efforts to identify the root cause and develop effective countermeasures were faltering.

Forecasts from the internal fraud team and a major consultancy brought in for support differed significantly, with potential losses estimated at 4–5 times the bank’s typical run rate. Under intense pressure, the internal team needed to produce a credible explanation of performance, actionable solutions, and a reliable forecast of future loss trajectories.

The consultancy’s initial approach was viewed as too costly, too expansive, and too slow to deliver the urgent results needed. We were brought in to take control of the situation, stabilise fraud performance, and implement impactful solutions at pace.

Our Approach

We rapidly launched a full-spectrum diagnostic in close collaboration with the internal fraud team to assess the control environment and identify exposure gaps. Applying deep risk and control expertise, we helped the team understand how operational vulnerabilities were driving fraud escalation.

Key actions included:

Rapid mobilisation of a structured programme with clear governance, defined accountabilities, and targeted resourcing across critical workstreams.

Driving engagement with all stakeholders involved in or supporting the fraud control environment, backed by enhanced reporting to spotlight weak points in defences.

Comprehensive deep dives into each perimeter control, prioritised by risk and thoroughly investigated.

Strengthening BAU operations through increased capacity, improved capability, and tactical enablers such as strategy refinement, process improvement, and productivity uplift.

Managing delivery through to full recovery — restoring fraud losses to baseline, embedding a revised operating model, clarifying ownership and accountability, and implementing forward-looking reporting with stronger leading indicators for preventative action and continuous improvement.

The Results

The bank successfully avoided significant further fraud losses.

Fraud performance returned to its natural run rate within 6 months.

The fraud function was stabilised with increased capability, a focused improvement plan, and a clear case for future investment.

Governance, accountability, and reporting structures were materially improved across the fraud defence perimeter — delivering a stronger, more predictive and transparent fraud control environment.

Snapshot Summary

Client: Major UK Mortgage Lender.

Engagement: Provide independent oversight and assurance over critical components of a core platform replacement programme, using our proprietary diagnostic methodology to identify risks, surface vulnerabilities, and offer actionable recommendations for improvement.

Outcome

50 high-value, actionable observations, aligned to key programme risks and vulnerabilities.

Key recommendations accepted and implemented.

The Challenge

Following earlier challenges with major consultancies, the client sought a targeted, non-intrusive assurance engagement to provide insight into selected aspects of a critical platform replacement programme.

Access to the programme was intentionally limited – with reliance placed on second line facilitation – and our insights were expected to be evidence-based, objective, and derived from documentation alone, without direct involvement in delivery.

We were asked to assess key areas highlighted in the oversight plan and provide the executive team with independent, high-quality input they could trust.

Our Approach

We brought structure, traceability, and precision to a light-touch, insight-rich engagement:

Central Repository & Traceability: Created a secure document repository, indexed all materials, and established full traceability between documentation, enquiry responses, and review outputs.

Diagnostic Methodology: Applied our proprietary diagnostic framework to assess programme documentation against structured criteria, surfacing systemic vulnerabilities and areas of risk.

Evidence-Linked Findings: Each observation was fully referenced to source materials, enabling leadership to see precisely where issues were emerging and how risks were distributed across the programme.

Collaborative Validation: Reviewed initial insights with second line leads to confirm accuracy and focus further enquiries.

C-suite Presentation: Delivered a structured report, clearly prioritised, categorised, and presented to the C-suite for direct consideration and action.

The Results

Within days of the report, several concerns highlighted were seen materialising, with programme leads acknowledging flagged risks and initiating changes.

Recommendations were taken forward, with clear ownership of issues established and greater internal confidence in oversight.

The engagement demonstrated that deep diagnostic assurance can be achieved even under constrained conditions — reinforcing the value of focused, evidence-led external insight.

Summary Snapshot

Client: UK Bank.

Engagement: Investigate, evidence, and recommend responses to an FCA request requiring the Chief Risk Officer (CRO) to attest that all necessary actions had been completed in response to previously identified failings.

Outcome

Investigations completed, evidence gathered, and targeted recommendations produced.

Gaps identified in ownership, progress, and status across the FCA’s findings.

A comprehensive report and plan prepared, enabling the CRO to respond confidently and transparently to the FCA, detailing progress, remaining actions, and closure timelines.

The Challenge

Following a series of regulatory concerns, the bank committed to a formal remediation plan to satisfy the FCA’s requirements. While ownership for different aspects of the plan sat across various functions, unclear accountability led to delays, omissions, and inconsistent execution.

Several months later, the FCA issued a formal letter to the Chief Risk Officer, requesting personal attestation that all issues had been fully resolved. Before responding, the CRO sought an independent and objective assessment of the bank’s position across every concern raised by the regulator.

We were engaged to investigate progress, assess the evidence base, and provide detailed recommendations against each point of regulatory scrutiny — ensuring that the CRO’s attestation would be defensible and comprehensive.

Our Approach

We initiated a structured, forensic review of the regulatory findings and the bank’s response to date. For each issue raised by the FCA, we:

Identified Ownership: Mapped each finding to its relevant business area and accountable executive.

Established a Central Repository: Created a single evidence hub to house all documentation and artefacts supporting the CRO’s response.

Defined Completion Standards: Clarified what constituted satisfactory resolution for each issue, the evidence required, and the standards to be met.

Engaged Executives: Brought accountable owners into structured engagement sessions, securing agreement on responsibilities, current status, and forward plans.

Captured and Assessed Evidence: Gathered documentation, assessed quality and relevance, and rated against the required evidential thresholds.

Produced Final Report and Recommendations: Developed a detailed report for the CRO and CCO, outlining the status of each issue, supporting evidence, and action plans for any gaps remaining.

Enabled Future Data Access: Designed a framework allowing the CRO to retrieve critical evidential data in future, should regulatory queries arise — safeguarding the attestation over time.

The Results

The CRO was able to submit a full, accurate, and defensible attestation to the FCA within the required timeframe.

All resolved matters were clearly documented; outstanding issues were transparently detailed with defined plans for closure.

The CRO was fully briefed to speak confidently to the regulator on the status of each item, the standards applied to determine completion, and the evidence supporting each assertion.

 

 

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