Robin Champion

The FCA’s ‘Vulnerability Review’ launch event will set-out its findings and next steps on March the 11th.  But looking back, where did the FCA’s vulnerability work begin? What have its milestones been?  And what difference has this ‘Vulnerability Decade’ made for firms and consumers? 2014: the first definition: "someone who, due to their personal circumstances, is especially susceptible to detriment" (Source: Consumer credit and consumers in vulnerable situations). 2015: the FCA definition expands: "someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care” (Source: Consumer Vulnerability, Occasional Paper 8).  The FCA include the TEXAS protocol in its Practitioners’ Pack. 2016: fieldwork for the first Financial Lives Survey begins, with this later famously reporting that 50% of UK adults (25.6 million people) display characteristics of potential vulnerability. 2017: the FCA consult on a new definition: "people who can readily be identified as significantly less able to engage with the market, and/or people who would suffer disproportionately if things go wrong" (Source: Our Future Approach to Consumers). 2018: the new definition is rejected – and the 2015 version rides again. The first cohort of the Vulnerability Academy begins (an award-winning six-month programme run by the Money Advice Trust and UK Finance). 2019: the FCA now goes further, publishing the first version of its draft Vulnerability Guidance for firms for consultation (Source: FCA GC19/03). 2020: the second draft of the Guidance is published. “Harm” replaces “detriment” in the definition: "Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care" (Source: FCA GC20/03). 2021: the FCA publishes its finalised Vulnerability Guidance – giving firms ‘six pillars’ of action to address consumer vulnerability and prevent harm (Source: FCA FG21/1). 2022: the FCA’s Consumer Duty is published, raising the standard of care for all consumers, but recognising vulnerability as key: ‘1.24 FG 21/1… remains relevant for firms, and firms should refer to it for further information on our expectations" (Source: FCA FG22/5). 2023: Consumer Duty rules come into effect for open products. Meanwhile the fourth Financial Lives Survey shares its findings on the Cost-of-Living crisis, and the tenth cohort of the Vulnerability Academy begins. 2024: the FCA announces it will undertake a formal review of firms’ treatment of vulnerable customers.  Consumer and firm surveys, deep-dive analysis, and information requests begin. 2025: the FCA organises a March 11th event to launch and discuss its Vulnerability Review findings, including firm progress and future expectations. These are our Vulnerability Decade moments.  What are yours?   Leave a comment below. 

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🚨 HMRC has launched its Crypto-Asset Reporting Framework guidance hub – a central source for updates and detailed information. More information here: https://lnkd.in/ebug9BCG ⚠️ One area not getting enough airtime: Reporting institutions must document all pre-existing "customers" within 12 months of the 1 Jan 2026 start date – or face a per-user penalty. That can add up 📬 Sending one letter and hoping for the best? Not likely to meet the “good faith” threshold. A unique twist: there’s also a penalty on the customer for failing to provide a valid self-certification. 🤔 What about including language on forms similar to the “penalties of perjury” clause found on W-8 forms? #CARF #CryptoTax #CRS #OperationalTax Peter Brewin Kit Dickson Elizabeth Stone Peter Churchill Nick Chouksey Pedro Malheiro Simon Leach Laura Talvitie James Moseley

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Our latest news: OneID® is now officially the UK's first certified digital ID wallet! We have been certified under the latest version of the Digital Identity and Attributes Trust Framework (DIATF), v0.4 (aka 'Gamma' version). The role of a wallet provider is also known as a 'Holder Service Provider' in government terminology. We were the 1st Orchestration Service Provider in an earlier version of DIATF, and are now the 1st 'Holder Service Provider'. What does this mean for OneID® wallet users? Privacy and control over your own data, faster access to things you need, and more security to protect you online. Our wallet is a cloud wallet, meaning it works on any device, cross devices with no app downloads required. Your data is stored and protected by your bank or telco operator.

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Shout out to my fellow data visualisation geeks. We all talk about vulnerability characteristics being overlapping and what this means for people's complex and unpredictable lives. This Venn diagram flower from FCA Financial Lives 2024 is a great way to show that (even if it takes some working through!) The Financial Lives Reports are absolute stacked with information - the challenges are making the time to get through them (approx 100 pages each...), and working out what it means for you. Within FS providers, there are three initial ways that I'd be using this information: 1. Understanding nature and scale of vulnerability within my target market - the data tables provide a huge amount of insight which can highlight which characteristics are most prevalent. This can be split by product holdings or by demographics. This is a great tool for prioritisation of activity and of future research. 2. Getting a starting view of the impacts of different characteristics - this year's reports have great insights on the barriers that people face in accessing products and services, and who is facing them the most. This is brilliant for an initial audit of your current customer journey and services. 3. Building the business case for internal changes. Half of the population have a vulnerability characteristic. Nearly 10m people have 2 or more drivers of vulnerability. When you're looking to improve outcomes for customers in vulnerable circumstances and struggling to get buy in, these data tables show that we're not talking about a handful of people. The opportunities are significant, both socially and commercially. At Inclusive Outcomes and the Big Window, we help businesses gain a deep understanding of the needs of customers in vulnerable circumstances, and then do something about it, in order to define, design and deliver good outcomes. And, we can help you make sense of this data too. Get in touch if you'd like to know more.

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🔇 For those looking for a quick fraud specific summary of the PSR Strategy Update for 2025, please see below: ⏪ 2024 Reflection The October measures have significantly enhanced consumer protection, which is helping to increase trust and enable more people to feel confident in embracing digital banking. The measures have also prompted positive change, with firms enhancing their efforts by investing, tightening controls, and tackling fraud with increased sophistication. ⏩ 2025 Outlook The core overall theme is that the PSR remains committed to decreasing the volume and value of APP fraud, but where it does occur, increasing reimbursement rates. This is done via: 📋 Commitment to review the impact of the October measures, including commissioning an independently led evaluation of the reimbursement requirements. 🤝 Support the FCA in leading a cross-sectoral approach to tackling fraud, including by helping to facilitate data-sharing between payments firms. 🧾 Summary Overall while no dazzling new initiatives are outlined, it is commendable to see the continued focus on fraud prevention, and we can expect to see the theme of cross-sector collaboration and data sharing continue as we head into 2025. https://lnkd.in/eJj9fRqH

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If you are in financial services and interested in GDPR, then my article in 'The Advantage' (the LIA magazine) is worth checking out. The point being that a continuous reliance on the consent basis of data collection isn't always the best choice, in particular for regulated entities. #GDPR #LifeTech #InsureTech #MortgageTech #regulation

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FCA Multi-firm Review on Off-Channel Communications: Leadership Accountability Under the Spotlight   The FCA has published findings from its multi-firm review of how wholesale banks manage off-channel communications - those conversations happening outside monitored, recorded channels. Here are the critical insights: - All 11 surveyed firms showed improvements over the past two years - Yet most firms still identify ongoing policy breaches - 41% of breaches involved directors and above - leadership accountability is crucial - 8 firms reported 178 breaches in just 12 months (with 131 concentrated in 3 firms) What's Working Well: ·      Updated policies covering new tech like smartwatches ·      Streamlined self-disclosure processes for staff ·      Enhanced surveillance using AI and natural language processing ·      Corporate devices with bright colours for easy identification on trading floors ·      Comprehensive management information Key Challenges: - Channel hopping - employees switching from recorded to unrecorded platforms - Third-party vendor reliability issues (service outages, data gaps) - Quality concerns with transcription services - Inconsistent MI frameworks Points to Consider include: ·      Do your employees fully understand their responsibilities? ·      Is your leadership setting the right "tone from the top"? ·      Are there unreasonable barriers preventing compliance? Pragmatism for now but clear expectations: The FCA isn't introducing new rules but expects outcomes-based compliance. With US regulators imposing billions in fines for similar issues, UK firms should treat this as a clear signal to strengthen their frameworks as soon as possible. Does your Market Abuse Risk Assessment (MARA) comprehensively and effectively cover off-channel communications risks? If you want confidence that you're meeting your obligations, our Kaizen Market Abuse Assurance team can help. We're conducting complimentary MARA framework health checks right now, just an honest assessment of where you stand. Worth a conversation? https://lnkd.in/ehHj4xGF #FCA #RegTech #MARA #MarketAbuse #Surveillance #ecommunicationsurveillance #voicesurveillance

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Worshipful Company of Information Technologists & City St George’s, University of London School of Science and Technology, ”Operational Resilience UK and EU Financial Services - An Operational Resilience Report on the Status of Financial Services in the Delivery of Regulatory Compliance” Their key messages and recommendations: Operational resilience goes beyond compliance, embedding into core operations ensures stability, sustainability, threat management, and stakeholder trust. Large Firms: - Embedding operational resilience into strategic objectives - Recognising the criticality of ICT systems - Addressing regulatory complexities Micro, Small, Medium Firms: - Promoting Continuous Compliance in the Firm - Integrating operational resilience into strategic objectives - Empowering senior leadership to provide an ongoing independent self-assessment - Ensuring transparency through reporting Cloud, Service Providers: - Clarifying the classification of important business services (IBS) - Defining cloud systems for financial services clients Third Party Service Providers (TPSP): - Automating compliance functions - Enhancing risk management - Strengthening scenario testing and collaboration - Revisiting the maturity framework for strategic planning Outsourcing Service Providers (OSP) - Allocate appropriate resource to ensure complaince - Engage leadership to adopt a strategic approach to operational resilience - Develop industry guidance for SME outsourcing firms CONCURRENCE ——— #datasharing #dataportability #concurrence #dataaccess #M2MI #aiagents #agenticai #automatedM2Mintelligence #datainteroperability #FMI #globalsupplychain #crossboarderpayments #securefinancing #fraudprevention #tradefinance #openbanking #fintechdataplatform #tradematters #sustainability #digitaltrade #globaltrade #FinancialMarketInfrastructure #technology #LEI #digitalidentity #C4DTI #paperless #digitalidentities #datasharing #innovation #digitalisation #paperlesstrade #digitaltransformation   #digitaltradechampion #digitaltradeevangelist #openfinance #internationaltrade #digital #crossbordertrade #smartdata #cbdc #regtech #suptech #payments #innovation #banks #digitalrevenueimpact #risk #regulations #digital #m2mi #cybersecurity #risk #banking #embeddedfinance #openbanking #sustainablefinance #iot #money #bankofengland #digitaleconomy #fintech #multicurrency #privacy #artificialntelligence

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Contact Centres at the Crossroads of Transformation After chairing last week's #BINA Contact Centre Summit in #Madrid, I came away with a sense of the scale of change that is underway. Over two days, leaders from across insurance, banking, retail, telecoms and technology explored the future of the contact centre and its evolving role. Through a combination of presentations, panel discussions, Q&As and roundtables the conference created a lively, interactive and rich knowledge sharing experience for all. Despite the range of industries, a common thread ran through the sessions: How can we reimagine contact centres as engines of value, not cost? As spaces of dignity, not just efficiency? Here are some of the core insights that stood out: - Recognition is a strategic lever. From Staffino’s Tomasz Rosputinsky to Belfius' François Gengoux, the message was clear. Employee recognition, love and purpose are not soft ideas. They are central to motivation, retention and improved CX performance. - GenAI is becoming real, but only with the right foundation. MasOrange, eGain, MEO and others presented real-world deployments including predictive routing, personalised coaching and AI-driven knowledge hubs. But they also emphasised the importance of high-quality data, thoughtful design and organisational alignment. Without these, GenAI remains superficial. - Speed is not everything. Adaptive speed is. Christos Katrisiosis of COSMOTE reminded us that while customers often value fast resolution, there are moments when empathy, clarity and care matter more. The real skill lies in knowing when to slow down and connect. - The truth lies in the dirty flows. Francisco Fernandez of Movistar Prosegur Alarmas challenged us to look beyond clean customer journeys and satisfaction averages. It is often the broken, complex, or hidden moments where dissatisfaction builds. Transformation starts by addressing these realities. - Ecosystems and platforms are reshaping the customer experience. AXA Partners, MEO and Medallia demonstrated how embedded services, automated triage and smart orchestration are shifting the landscape. Increasingly, the most powerful experiences are seamless, silent and intelligently embedded into daily life. - And perhaps the most important insight: The leading organisations are not just adopting tools. They are rethinking the purpose of the contact centre itself. Moving from resolving issues to building trust. From processing transactions to creating meaningful human experiences. A great thanks to all the speakers, attendees and the BINA team for their contributions to a rich, engaging and wide-ranging dialogue - and for letting me practice my Spanish! The challenge ahead is not simply how we optimise the contact centre, but how we redesign it as a place of purpose, empathy and value creation. #CX #ContactCentres #AI #GenAI #CustomerExperience #Leadership #DigitalTransformation #HumanCentric #PurposeDriven #FutureOfWork

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Less than a month to go until our virtual course with Risk Learning on the hottest topic at the moment - Operational Resilience. I am excited to deliver this course again with Andrew Sheen. We will cover all the essential elements of operational resilience, including mapping, testing and identifying and managing vulnerabilities arising from 3rd / nth parties. Also, learn how operational resilience relates to BCM and how the tools of ORM can be used to deliver better resilience.

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🔎 Customers have been loving Maxsight Investigations since it launched earlier this year and so is Datos. The 2025 AML Impact Awards have recognised Moody’s with a Silver Medal for Best Financial Crime Investigation and Reporting Innovation. Maxsight™ Investigations brings together data from proprietary, open-source, and internal case files into a single platform. It combines AI-driven analytics with human oversight to help investigators detect anomalies, uncover hidden connections, and collaborate more effectively. Find out how Maxsight Investigations is helping practicioners adapt to today’s complex financial crime landscape: https://lnkd.in/eMZkaW39

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Imagine regulation as a dynamic, real-time API. Could it keep pace with the growth of AI and cloud in UK financial services? Forget static rulebooks. We're facing a future where regulatory frameworks must adapt instantly. Are we therefore building sandcastles against a tidal wave of innovation?

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Surprise, surprise — but what’s the real news here? 🤔 According to the Financial Times, the FCA just revealed that UK banks are failing to stop a rise in romance scams — up almost 10% last year, with victims losing £106 million in 2024. 💔 One person even sent £400,000 to someone claiming to be a soldier overseas. And despite “clear indicators of romance fraud”, the bank still approved the payment. Honestly — none of this should surprise us anymore. We’ve seen this story play out again and again: 🚫 Missed red flags 🚫 Fragmented fraud monitoring 🚫 Silence between institutions and platforms The real story here isn’t just the scams. It’s that financial crime intelligence sharing is still too slow, too narrow, and too isolated. 💡 What we actually need: ⚡ Speed – near real-time sharing of alerts and typologies 🌐 Breadth – cross-sector visibility (banks, fintechs, telecoms, social media) 🔒 Security & trust – frameworks that protect privacy and enable collaboration Until we fix that, the same headlines will keep returning — just with bigger numbers and sadder stories. We can do better. We must do better. The tools are there — the will just needs to follow. 💪 What’s the one change you’d make to make fincrime intel sharing actually work? 👇 #AML #RegTech #FinancialCrime #Compliance #FraudPrevention #IntelligenceSharing

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