Consulting & Advisory

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Corporate, Wholesale and Investment Bank

Governance, Risk and Compliance (GRC) Section 166 Remediation Programme

A major global FTSE-100 financial services firm had one month to shape, scope and plan a 60-project programme of work in response to a Section 166 Skilled Persons Report requested by the Financial Conduct Authority (FCA). The firm also had to deliver all 60 projects over a twelve-month period with sub-deliveries due each month.

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The Client
A major global FTSE-100 financial services firm.
The Challenge

The firm had one month to shape, scope and plan a 60-project programme of work in response to a Section 166 Skilled Persons Report requested by the Financial Conduct Authority (FCA). The firm also had to deliver all 60 projects over a twelve-month period with sub-deliveries due each month.

The Solution

Lysis worked with the firm's board and senior management to shape each project and then produced a detailed programme plan which provided delivery dates. The client was then able to commit to the FCA. Lysis also established programme governance, RAID, and tracking tools to ensure accurate and timely delivery. Furthermore, Lysis worked with executive and senior management to initiate the programme and projects and to build the teams that were required across internal and third-party resources and responded to initial FSA challenges on the programme and project set-up. They also managed the global programme, spanning the Governance, Risk, Compliance, Operations, and IT functions and reported to a board-level steering committee. In addition, Lysis was directly responsible for, and resourced a number of workstreams covering:

- Programme management, planning, tracking, and reporting, including programme risks, issues, dependencies, and budget.

- Changes to global governance structures, boards, committees, and legal entity governance.

- Changes to governance of senior management remuneration.

- Revisions to group policies, delegated authorities and escalation arrangements.

- Enhanced the board-level management information (MI).

- Reviewed the role and effectiveness of NED's.

- Global and regional compliance policies.

- AML Review and Remediation.

- Operational Risk Management.

The programme under Lysis' overall management also included:

- Redrafting the role and activities of the audit committee.

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

- Arrangements for transaction reporting and market abuse detection.

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

- Risk management policies including ICAAP.

- Design and implementation of strategic planning arrangements.

Results

All milestones across the 12-month programme were achieved on time and under budget and all deliverables (several hundred in total) were accepted by the FCA. Lysis also ensured that all changes which arose from the programme were implemented and embedded in business as usual (BAU) within the firm. Confirmation was received from both internal audit and the appointed skilled person in their post-implementation reports that the firm had satisfied the requirements of the S166 report. This ensured an effective roll-out and handover to line management and regulatory restrictions on the firm were lifted.

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