When a regulator imposes requirements, commissions a review or restricts a licence, we deliver the remediation to the regulator’s timetable and restore the firm to normal supervision.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Supervisory action takes familiar forms: a requirements notice, a skilled-person or independent review, a restriction on new business, a request to hold additional capital, or a programme of remediation with a deadline. Each has a path back to normal supervision, and we have walked it with payment, e-money and cryptoasset firms in several jurisdictions.
The work combines a clear-eyed assessment of what the regulator wants to see, a remediation plan the board can commit to, and the delivery of that plan with evidence the regulator accepts. Where the firm’s banking is affected, we address it in parallel.
The regulator’s concerns read as the regulator reads them, with the root causes identified and the standard required set out.
A plan with owners, milestones and evidence, agreed with the board and, where appropriate, with the regulator.
Policies rewritten, controls rebuilt, backlogs cleared, staff trained and the evidence file assembled as the work is done.
Preparation for and management of a skilled-person or independent review, from scoping to the final report.
Every meeting, letter and attestation handled, with progress reported in the form the regulator expects.
Bank and partner relationships managed through the period, with the remediation evidence shared where it supports them.
| Deliverable | What it contains | Who relies on it |
|---|---|---|
| Root-cause assessment | The findings, their causes, and the standard the regulator requires | Board, regulator |
| Remediation plan | Workstreams, milestones, owners and evidence requirements | Board, regulator, reviewers |
| Evidence file | Completed work indexed to each finding, ready for review | Regulator, skilled person |
| Progress reports | Weekly board reporting and periodic regulator updates | Board, regulator |
| Closure submission | The case for lifting requirements with the supporting evidence | Regulator |
Yes. We prepare the firm for the review, manage the information flow and deliver the remediation the review recommends. The reviewer remains independent throughout.
Assessment starts within days of instruction. Supervisory timetables are short, and the first fortnight sets the plan the regulator will measure the firm against.
Regulatory requirements are often public or disclosed under the bank’s terms. We manage those relationships with the firm so that banks see a credible plan and evidence of progress.
Yes. Restrictions on new business, capital requirements and conditions on the licence are the usual starting point.
A fixed fee for the assessment and plan, then a monthly fee for delivery sized to the workstreams, agreed in writing.
A reply within three business hours and a written proposal on scope, cost and timing the same day.