FCA Section 166 Risk Mitigation Programme

A U.K. based broker dealer required assistance with the management of their Financial Conduct Authority (FCA) issued Section 166 remediation notice.

Division
Consulting & Advisory
Industry

Corporate, Wholesale and Investment Banking

Service-line

Governance & Compliance Framework/ Section 166/ SMCR

The Client

A U.K. based broker dealer.

The Challenge
Lysis Managed the FCA Section166 reporting to the Group COO. They worked with the firm's board and senior management to shape each project and then produced a detailed programme plan which provided the delivery dates included in the response to the report.
The Solution

The project included programme governance, RAID, and tracking tools to ensure accurate and timely delivery, working with executive and senior management to initiate the programme and projects, to build the team required and to respond to initial regulator challenges on the programme and project set-up. Lysis also managed the entire global programme, spanning the Governance, Risk, Compliance, Operations, and IT functions, reporting to a board-level steering committee. Lysis took responsibility for programme management, planning, tracking, and reporting, including programme risks, issues, dependencies, and the budget.

Results

Lysis assisted the client successfully with their S166 remediation requirements as per the FCA specifications and further proposed changes to the global governance structures, boards, committees, and legal entity governance which included:

- Senior management remuneration.

- The role and activities of the board and sub committees, and compliance with senior manager regime (SMCR).

- Group policies, delegated authorities, and escalation arrangements.

- Board-level management Information.

- The role and effectiveness of NEDs.

- Governance, structure, and operation of the compliance function.

- Global and regional compliance policies.

- Arrangements for transaction reporting and market abuse detection.

- Governance, structure, and operation of the risk management function.

- Risk management policies including ICAAP.

- The design and implementation of strategic planning arrangements.

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