Executive Strategic Counsel
Financial. Services - Insurance (multinational Group)
Regulatory Business Remediation Programme
12 Months
The Situation
A decision to expand into European clients had outpaced the organisation's governance and control maturity. Directors and senior managers lacked the skills the expanded business needed, the Board wasn't seeing timely or accurate management information, and a new underwriting and general ledger system had gone live without the pricing and reserving controls to match.
An over-focus on profitability ultimately led to a breach of the regulator's capital requirement (ICG) — the point at which the FSA's Arrow visit and Section 166 review became inevitable.
The Complexity
- The remediation ran as 13 simultaneous workstreams rather than sequential phases — most aligned to vertical operational areas, with horizontal streams such as HR working across all of them.
- The UK business sat at the centre of the structure, though ultimate control remained with the parent company in Japan, and European trading changes were routed through the German business.
- Governance ran on multiple tracks in parallel: a Steering Group for overall oversight, 1:2:1 sessions with UK executives, confidential conversations with the parent company's Chairman and his representatives, bi-weekly communication with Germany, monthly reviews with the FSA, and written regulatory updates to the JFSA and German regulator through the relevant business areas.
The Engagement
- Engaged as contract Programme Manager, I held full day-to-day authority over the Business Remediation programme — its definition, workstreams, resources, technical debt and enhancement, and a budget of circa £2.78m within an overall remediation programme budget of £6.1m — while reporting into the Chairman and Non-Executive Directors.
- I liaised directly with regulators across the UK, Japan and Germany, and with management teams across the business, seeking spend authority from the CEO and CFO where required.
CxO Counsel
Counsel throughout the programme ran through frequent 1:2:1 sessions, not just formal reporting.
- With the Head of Compliance, frustration at the CEO's response to risk and oversight recommendations was reframed — moving the conversation from "this is what you need to do" to "if we do this, we will benefit from these improvements" — opening a more collaborative dynamic.
- With the incoming CEO, counsel meant coaching him through the personal doubt of stepping into a CF1 role — the executive director accountable for directing the affairs of a regulated firm — working through what the role actually demanded against his own demonstrable strengths, until self-doubt gave way to genuine self-belief.
- With the most senior Japanese manager in the UK, counsel meant deliberately building a direct, respectful relationship that bypassed the traditional deference to hierarchy — becoming the channel through which decisions and support were secured directly, and decision lead times were cut in half.
"If we do this, we will benefit from these improvements."
KEY DECISION POINTS
One of the programme's biggest challenges was securing rapid decisions across a genuinely tri-cultural leadership environment:
- Japanese deference to hierarchy over direct conversation with senior management, German clear hierarchies and meticulous, technically-focused planning, and British consensus-driven, risk-averse, professionally hierarchical decision-making.
- Rather than working within any single style, the approach was to circumvent all three — building direct trust with the most senior Japanese manager in the UK, and communicating with him without hierarchy filters, always respectfully.
- That relationship meant decisions and his support could be secured directly, and teams were already cleared to act without the usual delay.
- The result: decision lead times cut by half, momentum maintained, and progress running ahead of both internal and regulator expectations.
Assurance Approach
Progress was never taken on a single reported status.
- It was triangulated across a Steering Group, 1:2:1 sessions with UK executives, confidential conversations with the parent company's Chairman and his representatives, bi-weekly contact with Germany, and — critically — monthly reviews directly with the FSA, with written updates to the JFSA and German regulator through the relevant business areas.
- Direct, regular regulator engagement meant the programme's real progress was tested against the people it ultimately had to satisfy, not just against internal reporting.
- Each reporting cycle was also measured against the plan I had agreed with the FSA to resolve noted issues. This was a key driver for the open communication and assessment of each work stream RAG status. The consistency of bi-weekly reporting lessened the overhead on work streams and communicated visible progress.
Outcome
- The remediation programme — with an overall budget of £6.1m, of which circa £2.78m sat under my direct day-to-day authority — cut decision lead times by half, and was completed a full month ahead of the regulator's deadline, resulting in the organisation's removal from the FSA watch list.
- NEDs, CxO and Chairman exposed to successful ways of communicating and working and delivering substantial change.
The Shift
- From an FSA Arrow visit and Section 166 review placing the organisation on the regulator's watch list → to full remediation and watch-list removal, a month ahead of deadline, underpinned by a new governance framework across three jurisdictions.
Service
This reflects Executive Strategic Counsel
"If your organisation is facing regulator-driven remediation, proven cross-jurisdictional programme leadership — and the executive counsel to bring your leadership team with you — can mean the difference between missing a deadline and coming off the watch list ahead of it.
Get in touch to discuss Executive Strategic Counsel."