Context and Challenge.
The client was a leading global MGA with operations in the UK and multiple overseas territories. The client was subject to regulatory oversight from Lloyd's and the FCA. Following a series of internal events involving senior leadership, the client was required to notify its regulators and provide formal undertakings to address governance and culture concerns.
The situation triggered a comprehensive review of governance structures, regulatory compliance, and risk management practices. Recognizing the sensitivity and urgency of the matter, the client engaged us to provide strategic advisory and delivery support across multiple domains.
Objectives.
The engagement was designed to achieve the following key outcomes:
- Remediate governance failures identified through internal investigations.
- Deliver regulatory undertakings and facilitate interactions with Lloyd’s and the FCA.
- Implement board effectiveness review (BER) recommendations and assess additional findings.
- Redesign and implement the risk management framework (RMF) to ensure alignment with best practices and regulatory expectations.
- Strengthen compliance and risk functions through targeted resourcing and operational support.
Approach and Delivery.
We deployed a director-led team, with deep expertise in governance, compliance, risk, HR and project management. The engagement was structured around a formal project governance framework, reporting directly to the client's group board and supported by a steering committee chaired by the CEO.
Governance and Regulatory Remediation.
We conducted a full review of the investigatory process and associated evidence, identifying governance failures not previously documented. Recommendations were made to address these issues, and we supported the client in managing all regulatory interactions, including coordination with third-party reviewers appointed under the undertakings.
A dedicated program manager ensured timely delivery of all remediatory actions with structured reporting and documentation processes established to maintain transparency and accountability.
Board Effectiveness Implementation.
The client had recently completed an independent board effectiveness review. We supported the implementation of its recommendations and conducted a supplementary review to identify any additional actions warranted by the findings of the investigatory process. This ensured that governance improvements were both comprehensive and responsive to newly emerging insights.
Risk Management Framework Enhancement.
Recognizing that governance reform must be underpinned by robust risk management, we undertook a detailed review of the client's risk management framework. This included:
- Refreshing core risk policies to ensure clarity, relevance and alignment with regulatory expectations.
- Updating the corporate risk register to reflect current exposures, controls and ownership.
- Facilitating stakeholder engagement sessions to introduce and embed new RMF tools, fostering a culture of risk awareness and accountability across the organization.
These activities were designed not only to improve documentation and structure but also to drive behavioral change and enhance the effectiveness of risk oversight.
Compliance and Risk Resourcing.
To support the delivery of these initiatives, we provided two senior consultants — one specializing in risk and the other in compliance — to work alongside the client's compliance director. This ensured continuity, subject matter expertise and capacity to manage the increased workload resulting from the governance and risk reform program.
Those resources helped the client create and implement a new compliance framework including underlying financial crime, conduct risk and data protection frameworks, policies and procedures.
Training.
Effective delivery of the change necessary required a number of areas of very specialist regulatory training to be provided to individuals at a variety of levels across the organization. We developed a bespoke training program which was delivered and logged to ensure a complete audit trail activity that could be used to demonstrate actions taken with the regulators.
Results and Impact.
The engagement delivered tangible outcomes across the governance, compliance and risk domains, including:
- A clear and actionable roadmap for governance remediation and change.
- The fulfilment of specific regulatory undertakings with proactive engagement and transparent reporting.
- Strengthened board oversight and committee structures.
- A refreshed and embedded risk management framework supported by stakeholder buy-in and improved tools.
- Augmented internal capabilities through targeted resourcing, training and expert support.
The client emerged from the engagement with renewed regulatory confidence, a more resilient governance structure and a risk framework capable of supporting its continued growth and innovation.
Key Learnings.
- Governance and risk are interdependent — effective remediation requires a holistic approach.
- Stakeholder engagement is critical to embedding new frameworks and driving cultural change.
- Independent oversight and delivery provide credibility and assurance in sensitive regulatory contexts.
