Business Issue
Recognising the criticality of safeguarding, and the likelihood of tech changes being necessitated by the FCA's proposed safeguarding rule changes (CP24/20), an UK electronic money institution (EMI) wanted to understand the operational implications. They wanted to maximise the time available to their tech team to develop, test and embed the changes and decided to supercharge their analysis by availing of fscom's expertise to deliver a practical, commercially-sound and detailed roadmap.
Solution
fscom's experts conducted a structured assessment of existing controls using the EMI’s internal control mapping tool. This involved document reviews, inquiry sessions with key stakeholders, and a systematic mapping of current practices against the proposed interim state safeguarding requirements. The fscom team identified control mitigations and delivered targeted recommendations, including, for example, for the development of the CASS resolution pack, the negotiation of arrangements with the safeguarding banking partners and readiness for future changes.
Benefits
The EMI gained a clear view of the maturity of its safeguarding controls and their alignment with the proposed interim rules. fscom’s practical and risk-aligned recommendations helped the firm enhance its control environment, improve documentation, and respond more effectively, and at pace.
Client
Feedback
The client valued the collaborative approach, particularly the interactive workshops, which supported a shared understanding of obligations and risk areas. fscom’s clear and actionable guidance was instrumental in translating regulatory requirements into meaningful control improvements. The EMI expressed confidence in its strengthened safeguarding arrangements and their alignment with broader compliance objectives.
