Our approach
How we examine the operation
We connect what happens in the operation to the evidence that supports it, and to the decisions management needs to take.
What the work connects
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Operating activity
What happens in the systems, records and teams
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Evidence
What the records, contracts and explanations show
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Decision and action
Who owns each action, by when, and what closes it
What we examine
We examine the points where commercial activity, contractual responsibilities and system records meet. By operating model we mean how the firm’s activities, parties, systems and responsibilities fit together. The areas below show where that model is consistent and where controls or responsibilities need to change.
Licensed activity and actual conduct
For the client journey, we map the products and services together with the entities and teams involved. We examine who introduces, promotes, contracts, approves, executes and manages the relationship, and set those roles against the firm’s permissions and its documented responsibilities.
Systems and execution
We review authorised views of customer relationship management systems and of trading and execution workflows, including user permissions and records. Against the process described by management, we test selected client journeys and exceptions.
Introducers and promoters
We examine introducer and promoter arrangements, including the activity performed and the communication channels used. That review also covers incentives, commission flows and oversight. The scope can include relationships between local and overseas entities.
Client money and operational controls
Where relevant to the engagement, we review the design and evidence of client money controls, reconciliations, approvals, segregation of duties and exception handling. Material calculations can be recalculated independently.
Contracts and communications
Agreements and disclosures are read alongside operating evidence, as are selected internal communications and customer-facing materials. This helps identify inconsistencies between contractual roles and actual behaviour.
Outsourcing and accountability
We examine what has been delegated and what each service provider is responsible for, together with access rights, oversight arrangements and records. We point out where it is unclear who owns an action and who checks or escalates it.
How we work
The work sets out the issues, what they mean for the operating model and the actions required. We agree the scope at the outset and discuss findings with the responsible teams before they are final. Progress is then verified against agreed evidence.
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Define the review
Agree the firm’s priorities, then settle which activities to review and which decisions the work should support. With the responsible teams, set the scope and the evidence required around the firm’s activities and objectives, and confirm the deliverables and schedule.
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Examine the operation
Follow selected client journeys, transactions and exceptions through the systems and teams involved. Compare actual practice with the documented process, and with the firm’s permissions and responsibilities.
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Establish the evidence
Cross-check system records, agreements and management explanations. Resolve inconsistencies and recalculate material figures where the review requires it.
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Assess the implications
Assess the evidence against the criteria agreed at scoping, such as the firm’s permissions, its own policies and the requirements identified by the firm and its legal advisers, and explain the effect on the operating model. Findings are reviewed for accuracy, significance and relevance.
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Plan and verify remediation
Develop a prioritised action plan with responsibilities, target dates and evidence of completion. Review implementation and re-test agreed items to assess whether the identified gaps have been addressed.
If re-testing shows that a gap is still open, the work goes back to step 3 and the evidence is established again.
What you receive
The initial engagement has seven core deliverables.
| Agreed scope and evidence index | The question, review period, entities and systems covered, with an indexed record of sources, requests and missing evidence |
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| Operating and licence map | A view of actual activities, parties, permissions and responsibilities across the customer, data and money flows |
| Systems and document review | A record of the processes, selected records, agreements and communications examined, including the limits of testing |
| Supported findings | Facts, source references, applicable criteria, analysis, impact and unresolved questions, distinguished from observations |
| Business model options | Proposed arrangements, conditions, dependencies and decisions where redesign is included in the scope |
| Prioritised action plan | Proposed actions, named or assigned owners, priorities, target deadlines and the evidence expected for closure |
| Management discussion and closure plan | A review of the conclusions, decisions needed, agreed follow-up and the basis for verifying remediation |
If the scope changes, we review the change with the firm and confirm its effect on priorities and delivery.
How we engage
The first discussion establishes the firm’s licensed activities, operating priorities and specific question. We then agree the scope, authorised information access, deliverables, timing and commercial terms before work begins.
What we agree with you
- The question the work should answer and the decisions it should support
- Entities, activities, systems and review period in scope
- Authorised information access and evidence handling
- Deliverables, schedule and commercial terms
What you can expect
- Findings discussed with the responsible teams before they are finalised
- Conclusions that state their evidence and any open matters
- A prioritised action plan with owners, dates and closure evidence
- Progress verified against the evidence agreed for closure