Operational Governance
Compliance Operating Model
For PSP · EMI · CASP · FinTech
A structured documentation package designed to describe the client's established or approved compliance operating model, including governance arrangements, reporting lines, functional responsibilities and interactions across business functions.
Areas covered
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Compliance Governance Structure
Preparation of documentation defining the organisational structure, reporting lines and governance arrangements for the compliance function.
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Roles & Responsibilities
Documentation establishing responsibilities across Compliance, Operations, Senior Management and supporting control functions.
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Compliance Operating Procedures
Development of documentation describing core compliance activities, decision-making principles and internal workflows.
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Management Reporting Framework
Preparation of documentation supporting compliance reporting, governance oversight and management information flows.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request
Internal Control Framework
For PSP · EMI · CASP · FinTech
A structured documentation package supporting the organisation and formalisation of client-confirmed internal controls, control ownership, segregation of duties and related monitoring arrangements.
Areas covered
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Control Framework Documentation
Preparation of documentation describing key internal controls supporting governance and regulatory compliance.
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Control Ownership
Documentation defining control responsibilities, ownership and accountability across operational functions.
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Segregation of Duties
Development of documentation supporting role separation, approval authorities and control independence.
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Control Monitoring
Preparation of documentation supporting periodic control reviews, monitoring activities and governance reporting.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request
Outsourcing Governance Framework
For PSP · EMI · CASP · FinTech
A structured documentation package supporting the formalisation of client-confirmed outsourcing governance arrangements, third-party oversight procedures, control responsibilities and exit planning processes.
Areas covered
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Outsourcing Governance
Preparation of documentation governing outsourcing principles, oversight responsibilities and governance arrangements.
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Critical Service Provider Classification
Documentation supporting the identification and governance of critical or important outsourced functions.
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Third-Party Oversight
Development of documentation describing monitoring arrangements, performance oversight and governance reporting.
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Exit & Continuity Planning
Preparation of documentation supporting transition planning, service continuity and outsourcing exit arrangements.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request
Risk Governance Documentation
For PSP · EMI · CASP · FinTech
A structured documentation package designed to establish governance documentation supporting enterprise-wide risk management and organisational oversight.
The package supports organisations formalising risk governance responsibilities, reporting structures and documented risk management principles.
It complements existing AML/CFT and operational risk documentation and does not replace risk assessments or day-to-day risk management activities.
Areas covered
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Risk Governance Framework
Preparation of documentation defining governance arrangements, oversight responsibilities and risk ownership.
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Risk Appetite Documentation
Development of documentation supporting risk appetite principles, governance objectives and decision-making criteria.
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Risk Reporting Structure
Documentation defining risk reporting arrangements, governance committees and escalation pathways.
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Governance Documentation Alignment
Preparation of documentation ensuring consistency across governance, operational and compliance documentation.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request
Board Governance Documentation
For PSP · EMI · CASP · FinTech
A structured documentation package designed to establish governance documentation supporting board oversight, management accountability and organisational decision-making.
The package supports organisations documenting board responsibilities, governance arrangements and management oversight within regulated financial services environments.
It complements existing governance frameworks and does not replace legal corporate governance requirements or board advisory services.
Areas covered
Board Governance Framework
Preparation of documentation defining board responsibilities, governance principles and oversight arrangements.
Delegation of Authority
Documentation reflecting decision-making authorities, delegated responsibilities and approval structures confirmed by the client's governing body.
Committee Documentation
Development of governance documentation supporting board committees, management committees and reporting responsibilities.
Governance Reporting
Preparation of documentation supporting governance reporting, board oversight and management information flows.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request
Agentic Operations Governance Documentation
For PSP · EMI · CASP · FinTech
A structured documentation package for organisations using AI or software agents within operational workflows involving internal systems, APIs, payment infrastructure or external service providers.
The package documents how client-defined agent permissions, decision rights, control ownership, access boundaries, exception handling and supporting evidence are reflected across the operating chain from human instruction to system action.
The work is based on the organisation’s existing or approved operating arrangements and control decisions. It does not include technical system design, cybersecurity assessment, legal or regulatory advice, compliance certification or independent validation of the underlying controls.
Areas covered
Agentic Operating Model & Decision Rights
Documentation of the operating chain between human users, software agents, systems and downstream services, including approved permissions, conditions, limits and approval points defined by the organisation.
Control Ownership & Access Governance
Documentation of agreed control ownership and responsibility for agent permissions, API and system access, credential lifecycle and related approval arrangements.
Exception, Escalation & Revocation
Documentation of defined stop conditions, exception handling, escalation pathways, human override arrangements and processes for restricting or withdrawing agent access.
Evidence, Audit Trail & Change Impact
Documentation of the business and control evidence retained across the authority → decision → action chain, together with documentation ownership and update triggers where relevant systems, permissions, providers, payment rails, digital assets or jurisdictions change.
Delivery
Approximately 3–4 weeks following completion of the intake questionnaire.
Format
Word / PDF
Written delivery only
Fee
Upon request