• The organisation had received negative feedback following a recent regulatory visit
• As a result, it had been the subject of an FCA Section 166 review
• A Skilled Person was in the process of being appointed to lead the s.166.

• Part of the regulatory assessment had identified a general weakness in the operating model that was in place to oversee the Financial Crime capability of the bank
• The bank had decided to set up a central Design Authority to oversee the programme of change and the design and set up of the new Target Operating Model (TOM).

• Supported the organisation throughout the review
• Sat on the Design Authority and provided SME insights around industry best practices and lessons learned
• Worked with the Skilled Person to agree the outcomes required to close TOM issues
• Revisited the target dates and managed regulatory expectations around achievability
• Baselined the plan across all TOM deliverables
• Defined the evidence required to back issue closure
• Provided a central control point for TOM related issues across the programme
• Worked with stakeholders to establish the key elements of the TOM
• Developed the Tom deliverables around People, Process, Systems & Controls
• Worked with individual issue owners to agree outcomes and timelines
• Managed the day to day risks, issues and dependencies across the programme.

• The organisation improved its underlying Fin Crime Operating Model
• We were able to re-baseline the programme and meet the revised dates
• Over the agreed timescale all issues were closed or mitigated to an acceptable level
• The Fin Crime BAU capability was improved and a sustainable model was put in place for the future
• The organisation improved its relationship with the regulator based on achieving the goals that were agreed.