Remediation

Independent Regulatory, Compliance & Financial Reviews

Not every business gets regulatory compliance right the first time. Whether your licence application has been rejected, your regulator has identified deficiencies, your investors require greater governance, or your business has simply outgrown its compliance framework, ComplyWorks provides independent reviews and practical remediation programmes that restore confidence and prepare organisations for long-term success. Our consultants work with regulated businesses globally to identify weaknesses, strengthen governance and implement sustainable solutions that satisfy regulators, financial institutions, investors and Boards. We don't simply identify problems; we help you solve them.

Who We Help

We support organisations at every stage of their regulatory journey, including:
  • FinTechs
  • Banks
  • Payment Institutions
  • Electronic Money Institutions (EMIs)
  • Money Service Businesses (MSBs)
  • Virtual Asset Service Providers (VASPs)
  • Crypto-Asset Service Providers (CASPs)
  • Investment Firms
  • Consumer Credit Firms
  • Wealth & Asset Managers
  • Insurance Businesses
  • Professional Practices
  • Estate Agents
  • Law Firms
  • Accountancy Practices
  • Gambling & Gaming Operators
  • High-Risk Businesses
  • International Financial Groups

Whether you are authorised, registered, applying for authorisation or preparing for expansion into a new jurisdiction, we can help.

When Should You Consider a Review?

Businesses typically engage ComplyWorks when:
  • A regulatory application has been refused.
  • A licence application requires remediation before resubmission.
  • A MiCA authorisation application has been unsuccessful or delayed.
  • Regulators have issued findings or remediation requirements.
  • Investors require stronger governance.
  • Banking partners have raised compliance concerns.
  • Internal audit has identified weaknesses.
  • A due diligence exercise has uncovered governance issues.
  • The Board lacks confidence in existing controls.
  • Compliance has become reactive rather than proactive.
  • Growth has outpaced governance.
  • The business cannot justify the cost of building a large in-house compliance function.

Whether you are authorised, registered, applying for authorisation or preparing for expansion into a new jurisdiction, we can help.

What We Review

Every engagement is tailored to your business and regulatory environment.

Our reviews may include:

Governance

  • Board Effectiveness
  • Corporate Governance
  • Senior Management Responsibilities
  • Committee Structures
  • Three Lines of Defence
  • Decision Making Frameworks
  • Board Reporting
  • Regulatory Accountability

Compliance Framework

  • Compliance Policies
  • Regulatory Mapping
  • Compliance Monitoring Programmes
  • Risk Assessments
  • Compliance Registers
  • Regulatory Reporting
  • Outsourcing Arrangements
  • Third Party Oversight

Financial Crime

  • Anti-Money Laundering Frameworks
  • Counter Terrorist Financing
  • Sanctions Compliance
  • Customer Due Diligence
  • Enhanced Due Diligence
  • Transaction Monitoring
  • Suspicious Activity Reporting
  • Fraud Controls
  • Business-Wide Risk Assessments

Financial Management

Strong financial governance is fundamental to regulatory confidence. We review:
  • Financial Forecasts
  • Capital Planning
  • Liquidity Management
  • Budgeting
  • Cash Flow Forecasting
  • Financial Controls
  • Management Information
  • Board Reporting
  • Operational Resilience
  • Wind-Down Planning

Whether you are authorised, registered, applying for authorisation or preparing for expansion into a new jurisdiction, we can help.

Ownership & Corporate Structure

Many regulatory delays arise because ownership structures have evolved without appropriate governance.

Our consultants review:
  • Group Structures
  • Shareholding Arrangements
  • Ultimate Beneficial Ownership
  • Governance Responsibilities
  • Group Oversight
  • Regulatory Reporting Lines
  • International Structures
  • Cross-Border Operations
Where appropriate, we recommend practical restructuring to improve transparency, governance and regulatory readiness.

Tax & Financial Efficiency

Working alongside trusted tax specialists where required, we help businesses review their financial structures to ensure they support sustainable growth while remaining fully compliant with applicable legislation.

This may include:
  • Group Structure Reviews
  • Cross-Border Expansion Considerations
  • Corporate Tax Planning Support
  • Financial Efficiency Reviews
  • Governance of Financial Operations
  • Investor Readiness

Regulatory Readiness Reviews

Many growing businesses do not require a large internal compliance department. Instead, they require confidence that their governance, systems and controls would withstand regulatory scrutiny.

Our Regulatory Readiness Review assesses whether your organisation is prepared for:
  • Regulatory inspections
  • Licensing applications
  • Investor due diligence
  • Banking due diligence
  • Internal audit
  • External audit
  • Mergers & acquisitions
  • International expansion
The result is a practical roadmap that prioritises improvements based on risk, regulatory expectations and commercial impact.

Global Remediation Support

Our consultants have experience supporting businesses across multiple regulatory regimes, including:

We understand that regulatory expectations differ across jurisdictions, but the principles of effective governance, financial resilience and financial crime prevention remain consistent. Whether your challenge involves MiCA, payment services, digital assets, professional regulation or broader corporate governance, we provide practical, proportionate solutions tailored to your regulatory environment.

Our Remediation Approach

Every project follows a structured methodology:

Independent Review

We assess your governance, financial management, systems, controls and documentation.

Gap Analysis

We benchmark your framework against regulatory expectations and industry best practice.

Remediation Plan

We prioritise improvements based on regulatory risk, commercial objectives and available resources.

Implementation

Our consultants work alongside your management team to implement agreed changes.

Ongoing Support

Where required, we provide ongoing outsourced compliance, governance and financial consultancy to ensure your framework continues to evolve with your business.

Why ComplyWorks?

Our consultants have decades of experience helping regulated businesses establish, strengthen and remediate compliance and financial governance frameworks. We understand the realities of operating regulated businesses because we have worked with start-ups, scale-ups, established financial institutions and international groups across multiple jurisdictions. Our advice is practical, commercially focused and proportionate; not generic. Whether you require a complete regulatory health check or targeted remediation following regulatory findings, we help organisations become stronger, more resilient and better prepared for future growth.

Speak to Our Specialists

If your business is preparing for authorisation, responding to regulatory findings, recovering from an unsuccessful licence application, strengthening governance or preparing for investment, ComplyWorks can help. Contact our specialists to discuss how our independent Review & Remediation services can support your organisation and build a stronger foundation for future success.

ICARA Compliance Support for FCA-Authorised Investment Firms

The Internal Capital Adequacy and Risk Assessment — the ICARA — is one of the most technically demanding elements of operating as an FCA-authorised investment firm. Under the Investment Firms Prudential Regime (IFPR), every authorised investment firm must maintain an ICARA document that demonstrates it holds sufficient capital and liquid assets to cover its harms and wind-down costs. For overseas firms entering the UK market, the ICARA is often unfamiliar territory. It requires financial modelling, scenario analysis, stress testing, and a clear understanding of how the FCA assesses capital adequacy. Getting it wrong — or submitting an inadequate ICARA — creates regulatory risk from day one.

What ComplyWorks Does

01.

Full ICARA preparation aligned to FCA and IFPR requirements

02.

Capital adequacy calculations under the IFPR framework

03.

Stress testing and scenario analysis

04.

Full ICARA preparation aligned to FCA and IFPR requirements

05.

Capital adequacy calculations under the IFPR framework

06.

Stress testing and scenario analysis

FCA Safeguarding Compliance for Payment and E-Money Institutions

Safeguarding is the mechanism by which payment institutions and electronic money institutions protect their customers’ funds. It is one of the FCA’s most actively supervised areas — and one of the most technically demanding to implement correctly. The FCA has taken enforcement action against multiple firms for safeguarding failures in recent years. For international firms entering the UK payment market, implementing a compliant safeguarding framework from the outset is essential — both for authorisation and for ongoing regulatory relationship management.

What ComplyWorks Does

01.

Safeguarding framework design under the Payment Services Regulations

02.

Safeguarding account structure and bank selection guidance

03.

Reconciliation procedures and monitoring frameworks

04.

Policies and procedures for ongoing safeguarding compliance

05.

Safeguarding audit preparation and regulatory reporting

06.

Remediation support for existing safeguarding deficiencies

FCA-Compliant Wind-Down Planning

The FCA requires every authorised firm to maintain a credible wind-down plan — a documented framework demonstrating that if the business were to cease, it could do so in an orderly manner without causing harm to clients, counterparties, or the wider financial system. For firms applying for FCA authorisation, the wind-down plan is a core submission requirement. For authorised firms, it must be kept current and stress-tested regularly. Poorly constructed wind-down plans are one of the most common reasons FCA applications stall — and one of the most common areas of supervisory concern for existing authorised firms.

What ComplyWorks Does

01.

Wind-down plan preparation for FCA application submissions

02.

Financial modelling of wind-down costs and capital requirements

03.

Liquidity analysis for the wind-down period

04.

Client asset and liability mapping

05.

Trigger events framework and escalation procedures

06.

Annual wind-down plan review and stress testing

Frequently asked questions

Straight answers to the questions firms ask us most often before starting a UK regulatory process.

Regulatory remediation is the structured process of correcting compliance deficiencies identified by a regulator, auditor, investor or internal review. It usually covers governance, systems and controls, documentation, and the evidence needed to show the improvement has held over time.

The common triggers are a rejected or stalled application, a regulator raising deficiencies, an investor or acquirer performing due diligence, entering a new jurisdiction, or a business that has simply outgrown the compliance framework it was built on.

A section 166 review is where the FCA requires a firm to appoint an independent skilled person to report on a specific area of concern. It is expensive and disruptive, and firms that address weaknesses proactively are in a materially stronger position than those that wait for one to be imposed.

Answer precisely what was asked, within the deadline, with evidence rather than assertion. Partial or defensive responses tend to widen the scope of regulatory interest. Where an issue is real, setting out the remediation plan and timeline alongside the answer is usually better received than omission.

It depends on whether the gap is documentation, systems or culture. Documentation gaps can close in weeks. Control and systems changes typically run for several months. Where a regulator expects evidence that a change is embedded, expect to demonstrate sustained operation over a number of reporting cycles.