Regulatory Change Programme for Operational Resilience

Client background 

Our client was a global interdealer broker that employed c. 10,000 people.

The challenge 

Our client required a partner to oversee a programme of activity to deliver the requirements for the FCA operational resilience regulation. Three legal entities within the group either fell into scope of the regulation or were expected to fall into scope soon after the regulatory deadline, which was six months away.

Our approach and contribution 

Working in close partnership with the firm we:

  • Mobilised a team of consultants to work alongside the client’s own staff to deliver the programme across several workstreams aligned to the regulatory requirements. 

  • Managed delivery of the programme, including project management of the individual workstreams and the programme’s Steering Group and project Working Groups. 

  • Managed risks and issues across the programme. 

  • Delivered process mapping for the firm’s Important Business Services using the BusinessOptix process modelling platform. 

  • Authored the various methods applied for identification of Important Business Services, Impact Tolerance Setting, Resource Mapping and Scenario Identification & Testing. 

  • Facilitated the operational resilience self-assessments and authored the self-assessment documents for each legal entity, including delivery of a method for traceability back to the regulations. 

  • Designed an operating model to support ongoing embedment of the operational resilience activities across the three entities. 

The outcome 

As a result of our engagement: 

  • The programme successfully achieved approval of the operational resilience self-assessments by the three legal entity Boards, within the compliance timeframe.  

  • A comprehensive framework to support operational resilience was successfully rolled out, including a Target Operating Model to support further embedment of the framework across the firm. 

  • The programme delivered a comprehensive suite of evidence to support the firm’s case for compliance with the FCA ‘Building operational resilience’ regulation. 

  • Existing vulnerabilities to the firm’s operational resilience of its Important Business Services were identified, enabling planning of remediation. 

We were subsequently re-engaged to provide additional support to the client in embedment of the framework and to co-ordinate the first quarterly operational resilience self-assessment update to two of the Boards.