Case study

Designing a Closure and Validation framework to keep a high-risk DOJ remediation on track

Lead partnerAl Catto

Our client, a leading European banking group, had entered into a Plea Agreement with the US Department of Justice following serious failings in its AML and financial crime controls. A large-scale remediation was already in flight, but it soon became clear that the programme risked going off track. There was no shared definition of what ‘complete’ looked like, and critical decisions lacked the governance needed to stand up to regulatory scrutiny.

BeyondFS was brought in to restore control. We identified the need for a robust Closure and Validation framework – one that would ensure the programme met its obligations, that completion criteria were consistently applied, and that every decision was backed by clear, auditable evidence.

Industry segment
European Bank
Function
Remediation
Core capabilities
Assurance design and delivery

Key outcomes delivered

A robust, adaptable closure and validation framework enabling focused, timely discussions with the right stakeholders.

A scalable and consistent process tailored to meet regulatory requirements and priorities.

Confidence that the programme met the Plea Agreement obligations, and that any residual risks or open observations did not undermine its completion.

Results

Programme management

0 /3

of workstreams rated ‘high maturity’ (up from a predominantly ‘low maturity’ baseline)

Delivery

0 -70

milestones plotted per workstream, improving delivery discipline

Training

internal staff trained by BeyondFS on programme delivery

Approach

Creating confidence in closure

BeyondFS was engaged to adapt and implement the closure and validation framework. To do this we adopted a modified version of a proven process we had developed in a previous Financial Crime remediation programme.
We formed a small, specialised team to work alongside the bank’s internal staff, focusing on:
- Establishing a structured governance check (Stage Gate) to confirm evidence was in the correct state (final, approved, locked) and that governance protocols had been followed.
- Introducing design validation – a desktop review by 2nd or 3rd Line of Defence SMEs to confirm that the evidence demonstrated objectives had been achieved.
- Setting up check-and-challenge forums, where SMEs critically reviewed projects before closure.
- Implementing a period of post-closure operational testing to assess the process's embeddedness and effectiveness, depending on its frequency.
This approach ensured that any issues were identified early, while also providing layers of confidence for the bank’s certifiers and regulators.

Outcome

From risk to resolution

With the new framework in place, the client’s senior leadership was able to focus on evaluating whether the programme's outcomes were achieved and assessing any remaining risks.

The governance structure ensured that the evidence and processes were consistent and fit for purpose, allowing the programme certification to proceed with confidence.