Delivering a Regulatory Change project

The challenge:

Our client, a global insurance broker, had a number of Regulatory challenges including 11 Risk Mitigation Programme (RMP) actions, a Section 166 review, an enforcement and additional commitments to the FCA. To mitigate and resolve these actions, they appointed Hydrogen to provide an independent view on progress, with a focus on early intervention/remedial action.

Our solution:

We aimed to deliver Regulatory Change to the business, removing the enforcement and leaving a framework for the future. We supplied a fixed price team to review over 5,000 high net worth, high individuals, many from high risk jurisdictions.



The team was led by a Programme Director and included:

  • 3 Project Managers,
  • 3 Business Analysts and
  • 1 PMO Manager

A Robust Programme Governance Framework was agreed by, and reporting up to, the Board, assuming the delivery liability at a fraction of the Big 4’s cost. We mobilised a team of eight, and fully scoped the project and delivered change to the business within just two months.

The outcome:

  • ABC Skilled Person (S166) Review successfully delivered
  • FCA enforcement findings were addressed, all enforcement actions stopped
  • The work was signed off by the FCA
  • The project was completed in 15 months, to budget
  • Delivered a legacy without dependency to manage Regulatory issues and initiatives going forward
  • The project cost £1.5m to deliver, saving 41% versus the next competitive quote, and preventing a £150m fine