Remediation and Section 166 Support

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Supporting firms following regulatory failings, supervisory action or enforcement intervention

When a payment, e-money or financial services firm fails an audit, receives adverse findings from an FCA inspection or becomes subject to supervisory or enforcement action, the priority is stabilisation, remediation and credible engagement with the regulator.

Payment Practice supports firms that are under regulatory pressure and need experienced, practical help to regain control, restore compliance and demonstrate progress ahead of further regulatory scrutiny.

We work with firms that have suffered regulatory failings, business restrictions or enforcement outcomes and need to put a clear and defensible plan of action in place.

We are typically engaged where a firm has experienced one or more of the following:

• Failed an internal, external or regulatory audit
• Received adverse findings from an FCA supervisory visit or inspection
• Been required to remediate weaknesses in governance, controls or systems
• Had services restricted, suspended or limited by the FCA
• Been prevented from onboarding new customers
• Had client accounts frozen or business activity curtailed
• Been issued with a skilled person review requirement or informal remediation mandate
• Is preparing for a re-audit, follow-up inspection or regulatory panel review

In these situations, firms often need immediate support that goes beyond policy drafting and focuses on real operational change.

We are not appointed to the FCA’s skilled person panel and do not act as the Section 166 reviewer.

However, we have extensive experience supporting firms before, during and after skilled person reviews and similar regulatory interventions.

Our role is to work alongside management, compliance teams and legal advisers to help firms:

• Understand the scope and implications of the review
• Prepare documentation, evidence and management information
• Address known weaknesses before or alongside the review
• Implement remediation actions arising from findings
• Stabilise governance, controls and oversight arrangements
• Prepare for re-engagement with the FCA following the review

This support is often critical in ensuring that remediation efforts are structured, credible and aligned with regulatory expectations.

A key part of our work is helping firms design and deliver a clear remediation plan that the FCA can have confidence in.

This typically includes:

• Root cause analysis of identified failings
• Prioritisation of regulatory risks and weaknesses
• Development of a structured remediation roadmap
• Clear ownership, timelines and governance oversight
• Practical implementation support rather than theoretical fixes
• Ongoing progress tracking and management reporting

We focus on ensuring that remediation addresses not just symptoms, but the underlying causes of regulatory concern.

Following enforcement action or supervisory intervention, firms are often subject to follow-up audits, further inspections or panel reviews.

We provide ongoing support to help firms prepare for these events by ensuring that:

• Remediation actions have been fully embedded
• Governance and oversight arrangements are operating effectively
• Evidence is available to demonstrate sustained improvement
• Management can clearly articulate changes made and lessons learned

Our aim is to help firms return to a stable footing and reduce the risk of further regulatory escalation.

Our approach is hands-on, discreet and proportionate to the seriousness of the situation.

We work collaboratively with senior management, boards, compliance functions and external advisers, providing calm and structured support at a time when firms are often under significant pressure.

Engagements may be short-term and intensive or structured as ongoing support over several months, depending on regulatory expectations and the firm’s position.

We specialise in payments and financial services regulation and understand how the FCA supervises firms in practice.

Our experience allows us to focus on what regulators expect to see, how remediation is assessed and where firms commonly fall short when under scrutiny.

We help firms move from reactive firefighting to controlled and credible recovery.