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Services
Regulatory Audits as a Service (RAaaS)
Our patented* RAaaS model offers a unique 'blended' approach to auditing and reduces the time, cost, and pressure to your teams.
By combining traditional techniques with behavioural dynamics, RAaaS delivers added insight to help you drive change and improvement giving you digital tools and algorithms to see where the key issues are allowing your teams to 'do the right things' as well as 'doing things right'.
Our unique approach not only takes the stress and uncertainty out of audits, it provides a non-bias, scalable, consistent solution ensuring you always remain aligned to the regulatory requirements and FCA principles.
Meeting the specific needs of Agents and Distributors working with a principle EMI, each audit is measured against current EMI regulations and the FCA principles-based regulatory risk management framework.
RAaaS can also be used as a health check or internal audit to give you a 10x improvement on your Compliance, AML & CTF spending.
* Patent No 20060206287
RAaaS
Agent & Distributor Assurance
Agent and Distributor supervision is a focus area of the FCA's strategy.
If the correct culture between the principle EMI and the Agent & Distributor exists and is managed well there can be a very constructive relationship. However, achieving this consistently in practice is not easy.
The principal EMI has conflicting customer and supervisory roles, whilst Agents and Distributors frequently have role/knowledge gaps and misunderstandings of the operational processes they need to have in place.
The FCA and other regulators have had to actively intervene on too many occasions recently, with very serious and expensive consequences for EMIs, Agents & Distributors.
Our services allow EMIs and their Agents & Distributors to be able to evidence that they are 'doing the right thing'.
Agent & Distributor Assurance
Dormant Funds Administration
EMI Dormant Funds Administration
We specialise in Dormant EMI Fund Administration, so you don't have to.
If you have EMI pre-paid card 'breakages' or dormant funds on EMI payment accounts we can substantially reduce your risk.
Outsource the administrative burden of dormant funds to us. You retain the Client Funds under your own EMI licence, we take the administrative burden off you and allow your team to focus on higher-priority activities.
Most EMIs that have Dormant Funds, or card breakages manage these badly and risk falling foul of new Consumer Duty regulations.
EMI Dormant Funds and card breakages carry serious risks in wind-down planning and particularly serious risks in a wind-down scenario.
Cifas Implementation
Fraudsters are getting more sophisticated and new regulations will make APP fraud even more expensive for EMIs and regulated firms.
With the UK's largest cross-sector fraud-sharing databases, Cifas is a not-for-profit organisation with over 600 members working to reduce and prevent fraud and financial crime. Many EMI, Agents & Distributors leave the implementation of Cifas too late and suffer as a result.
Cifas is an extremely powerful, but non-trivial system to implement for many organisations. Our project teams are able to speed up the process, reduce the risks allowing you to reduce your fraud, AML & CTF exposure quickly and effectively.
CIFAS Implementation
Interim Management
Interim Management
Finding the right skill set for your growing team can be a challenge.
When you are growing we can support you with a 'fractional role' - giving you access to senior people on a part-time basis as you grow.
Sometimes people leave at short notice in mandatory roles. We have a network of experienced Finance, Fincrime, MLROs, Compliance, and Operations interims who can provide the senior skills your business needs at short notice, whilst you take the time to recruit your ideal candidate for the permanent role.
Regultoy License Support
EMI Regulatory Licence Support
When your business is going well - you might outgrow or be 'inappropriately large' to be an Agent or Distributor for your principle EMI.
Your principle EMI's evolving risk appetite may no longer accommodate your expanding business or in more challenging scenarios, your principal EMI might face service restrictions imposed by the regulator. This can seriously damage or even kill your own business.
Many Agents and Distributors seriously underestimate the responsibilities, skills and complexity of being an EMI rather an Agent.
We have extensive experience in not only applying for regulatory licences, but also working at all stages of EMI growth.
We work alongside you as you plan and make the transition to your own licence.
EMI Wind Down Planning
EMI Wind-Down Planning
This is a mandatory FCA requirement and needs to be done before, not when you need it.
The FCA is rightly focusing on this area:
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FCA Strategy
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Dear CEO letter from March 23
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FCA Wind-Down Guidance
Our services are designed to minimise distractions to your teams from 'run the business' activities.
The FCA's Dear CEO letter highlights that many firms don't have a plan (at all) yet alone one that would actually work.
We have designed and combined the RAaaS and our wind-down assurance services to work together with Green Swan Financial to give the EMI industry access to a pragmatic and effective Wind-Down Assurance solution for dormant funds.
So, if you ever hit a wind-down trigger, or need to execute your wind-down plan, you have a partner and friend alongside you to help.
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