Regulatory gap analysis: Vocalink fined £11.9m for a compliance failure under the Banking Act 2009
The Bank of England recently issued its first fine under the Banking Act 2009, £11.9 million to Vocalink, the firm behind most UK payments.
The reason? Vocalink failed to meet a regulatory deadline to adequately address system and control weaknesses, despite having a remediation plan in place. Weaknesses in governance, risk management, and internal controls meant the plan wasn’t effectively delivered.
Monzo was also fined by the FCA for failing to properly implement and monitor a remediation plan, leading to thousands of high-risk customers being onboarded in breach of restrictions.
These cases send a clear message:
It’s not enough to have a remediation programme. It must be well-governed, resourced, and actively managed.
Effective remediation requires:
Clear objectives, ownership, timelines, and resources
Ongoing tracking and re-baselining where needed
Fit-for-purpose outputs and deliverables
Timely escalation and resolution of risks and issues
We’ve completed a gap analysis to help firms assess and strengthen their remediation governance.
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