White Paper: How to deliver successful regulatory remediation programmes

Remediation programmes tend to address shortcomings in three main areas: 

• Compliance and risk management: This includes missing risk assessments or inadequate controls that violate regulations. 
• Data and documentation: Inaccurate or outdated information that needs correction to meet compliance standards. 
• Culture and practice: Ineffective compliance frameworks, often due to a mismatch between written policies and real-world behaviour. 

Poorly handled remediations can result in serious problems, such as increased compliance costs due to haphazard fixes that address symptoms rather than root causes, and excessive staff turnover caused by high programme intensity and the pressures that accompany repeated delays or failure to achieve objectives over a long period. 

Institutions rarely approach remediations in a way that is suited to their unique regulatory demands. They normally structure them like regular change programmes, with the additional handicap of a knee-jerk, reactive approach. 

When a remediation is triggered by unexpected issues like internal audit findings, the initial urgency to fix these problems quickly fosters unrealistic expectations. Project teams overpromise quick solutions under pressure from senior management, setting themselves up for under-delivery. 

We recommend three critical tools to embed in a remediation programme from the outset: 

• Programme Management Office (PMO): acts as the programme's central hub, providing guidance, leadership, and progress updates. It facilitates decision-making on resource allocation and conflicting priorities. 
• Definition of Done (DoD): a set of agreed-upon criteria that each workstream must meet before completion. This ensures clear goals and prevents scope creep. 
• Programme Closure Framework: defines the steps necessary for closing milestones and workstreams. This allows stakeholders to effectively challenge decisions and encourages speedy resolution.