Transcript
What evidence-led remediation looks like A fictional example
Define the problem precisely In a fictional firm, some screening decisions do not explain why potential matches were discounted. That is an evidential gap, not proof that every check failed.
Understand the cause Read the records and management responses. Trace actual working practices. Here, the decision form omits identifier comparisons, and reviewers use inconsistent practices.
Set a corrective action Change the process as well as the policy. Add decision fields, train reviewers and identify affected live relationships. Assign an accountable owner and realistic deadline.
Keep historic and current positions separate Separate the historic position from current improvements. A later re-screen may reduce current risk, but it cannot show that an undocumented historic decision happened. Record both positions clearly.
Retain attributable evidence Retain the source screening result, the identifier comparison, the reasoned decision and any escalation. Link them to the correct relationship and record who reviewed the decision and when.
Agree the test before testing Agree the population, sample rationale, test period and success criteria before testing. Observe the control in use. Justify the sample for the actual risk.
Challenge the result A reviewer appropriately separate from delivery compares records with the approved process and seeks contrary evidence. Investigate exceptions, correct material problems and retest.
Make closure an evidenced decision Implementation and effectiveness are different stages. Close the action only when the agreed criteria are demonstrated and material exceptions resolved. Record the evidence, limitations and authorised closure decision.
Keep oversight working Report progress, remaining exposure and testing results to the Board. Continue monitoring after closure to detect repeat issues. The firm retains its ongoing responsibilities.
Use the right support MEMA supports preparation, operational review, remediation and testing, with appropriate separation for independent assurance. Use the free resources. An independent report does not itself constitute FCA approval.