Finance BCBS239 / RDARR Compliance Rectification

Following a regulatory inspection, the client was found non-compliant with BCBS239 requirements dating to 2016, with new RDARR obligations increasing the compliance gap. The Regulator had imposed a tight deadline for rectification and enduring compliance. The data ecosystem was fragmented, manually driven and heavily reliant on SAS and spreadsheet-based processes, with persistent Risk and Finance data alignment issues from years of underinvestment and siloed ownership. Neither the client nor its existing partners had the breadth of expertise across Business, Regulatory, Technology and Operations to address the overlapping regulatory demands concurrently.

A rapid assessment uncovered a lack of detail in the group-wide scope, a large number of unknowns in the legacy spreadsheet/SAS landscape, and false senior-level comfort from an overly simplistic delivery plan. We outlined a Strategy and Roadmap aligning Business, Regulator, Technology and Operations, and ran two parallel delivery streams, near-term RDARR compliance and longer-term architectural remediation, using an Agile-at-scale approach with proactive blocker management and embedded capability-building from the outset.

During our engagement, we embedded core data management principles and procedures on the client side, including data ownership, governance, data lineage, and profiling, as the foundation for a robust, enduring data quality and remediation process. Within our tenure, the compliance stream was brought fully in line with the regulatory deadline, independently validated through second-line-of-defence governance. We identified early that the longer-term remediation stream required urgent internal sponsorship and funding, flagging this risk to senior stakeholders in good time.