“Breaking eggs” to help a global bank avoid regulatory fines
Restructuring and budgetary challenges within a global bank had resulted in its European Division experiencing delays on a number of changes that had fixed deadlines imposed by the local banking regulators. One of these changes involved the inter-bank payment system in Belgium, which required an upgraded IT system and a revised authority process.
The regulators had the power to impose fines for lack of compliance.
Our task was to implement the changes, including obtaining budget approval, within a three-month period.
The bank’s internal procedures were built around providing secure systems to avoid reputational risk. As a result, they did not facilitate changes with tight deadlines – especially as a third-party supplier would need to access bank-owned equipment to make the change.
To deliver, we had to break some guidelines.
What we did
First, we identified key barriers. The first barrier was a “no engagement without secured budget” rule, and budget approval was taking up to two months.
The second barrier was a “one size fits all” pre-live test requirement that could not be comprehensively shoehorned into the three-month schedule.
We challenged the finance controllers, requesting and securing an unconventional “provisional” budget clearance.
We then created a plan that focused only on testing the critical elements.
Finally, we identified the senior managers who would need to approve this exceptional procedure, and worked with them to eliminate their fears and secure their approval.
The change was delivered within the imposed deadline.
The exercise forced the bank to revisit its “one size fits all” approach. As a result, it introduced a more flexible procedure based on our work, and this is currently being used throughout the entire organisation.