Q&A: Fintech: monitorships, independent reviews and compliance transformation

December 2026  |  SPECIAL REPORT: FINTECH

Financier Worldwide Magazine

December 2026 Issue


FW discusses monitorships, independent reviews and compliance transformation in fintech with Stella M. Mendes, Jaco Sadie, Andrew McCarthy, Ayse Duran and Mike Walters at FTI Consulting.

FW: How has the landscape for monitorships, independent reviews and compliance transformation changed over the past 12-18 months? What trends are having the greatest impact on fintech organisations today?

Mendes: I have recently observed an increase in requirements around monitorships, independent reviews and independent oversight, where regulators have become quite active in that space. From the world I focus on, regulators are still very focused on anti-money laundering (AML) gaps and weaknesses, with specific focus in the fintech space. Fintechs are newer to the market, so their compliance programmes may not be as robust as traditional financial institutions (FIs). As a result, they have had to remediate and strengthen their programmes. And because they are fast-growing companies, sometimes the pace at which they are growing is faster than their compliance programmes can keep up.

Sadie: There continues to be monitorships and independent consultant reviews enforced by regulators at both the federal and state levels, which are driving a compliance standard aligned with regulatory requirements and emerging industry best practices. Simultaneously, there has been a clear indication from regulators that compliance programmes should be more risk-based, practical and cost-effective, rather than overly burdensome. I still see many fintechs struggling to keep pace with compliance. Much of this stems from the speed and scale of growth they can achieve. Before the digital age, traditional banks simply could not grow at this rate. Fintechs operate online rather than face to face, so rapid expansion can create significant compliance challenges. As customer volumes increase, pressure on compliance functions grows just as quickly. Fintechs that fail to maintain strong compliance programmes or evolve the technology supporting those programmes risk falling behind regulatory expectations and industry standards.

McCarthy: Broadly, the landscape for monitorships has been fairly consistent. There is continued need and pressure, particularly in the AML and sanctions spaces, as regulators aggressively pursue compliance programmes that are not meeting relevant Bank Secrecy Act AML and sanctions requirements. The actors pursuing these enforcement actions and subsequent monitorships have changed somewhat. We are seeing more activity at the state level. Historically, this has been the purview of the federal government, but we are seeing greater involvement from states, and it is not just New York. Another development is the nature and use of analytics, particularly artificial intelligence (AI), both by organisations subject to monitorships and by the monitors themselves as they employ advanced analytics to perform these sensitive engagements.

Duran: In Europe, there is a continued push toward harmonising supervision across member countries. As with many European Union (EU) initiatives, creating a unified framework across countries and organisations is not easy, but efforts like the EU AML framework aim to establish more consistent regulatory standards. For fintechs, that makes topics like cross-border governance and data sharing increasingly important. In the US, we are seeing more state regulators enter the picture, increasing pressure on fintechs. As fintechs expand into products traditionally offered by banks, regulatory expectations are growing. Adapting to that environment takes time and requires changes in how fintechs operate and manage compliance. A hygiene factor that regulators are emphasising, and monitors should focus on, is strong documentation, even if it does not naturally align with the fast-moving culture many fintechs prefer. Concurrently, there is greater emphasis on proving that controls are effective and sustainable. The bar for demonstrating that compliance programmes actually work has become much higher.

Walters: The landscape for section 166 skilled person reviews in the UK has changed somewhat over the last 12 to 18 months. They are increasingly being used as a supervisory tool to give regulators insight into firms’ control environments, rather than as enforcement tools supporting actions such as fines. According to statistics published by the UK Financial Conduct Authority for 2025-26, relatively fewer skilled person reviews are being conducted at commercial or consumer institutions and more at non-bank financial services firms. My sense is that many of those organisations under review are fintechs, which suggests the section 166 tool may be used disproportionately in that sector compared with global FIs. I cannot definitively support that conclusion, but I do think that is what the statistics imply. Published figures categorise reviews between portfolio managed firms of various sizes, and the majority appear to be taking place in the latter group.

“There are two regulatory areas that are particularly important. One is financial crime, primarily AML and sanctions. The other is the safeguarding of client assets.”
— Mike Walters

FW: As regulatory expectations continue to evolve, where are fintech organisations experiencing the most significant compliance, governance and control challenges?

Walters: There are two regulatory areas that are particularly important. One is financial crime, primarily AML and sanctions, where we often see immature control frameworks, policies, procedures and technology implementation. The other is the safeguarding of client assets. FIs are entrusted with looking after other people’s money, so weak controls in this area always present significant regulatory risk. Beyond those two areas, one thing regulators almost invariably ask to be assessed is governance. Regulators want to understand the governance framework that sits across these control pillars, whether that is financial crime, AML or safeguarding client assets. That includes board oversight, executive leadership, the three lines of defence, reporting to the board and the level of challenge provided to senior management. In my experience, the strength of that overarching governance framework is a key area of focus in almost every review.

Duran: With the customer base so broad and access so easy, fintechs have quickly become one of the key channels for conducting and facilitating financial activity. They are no longer peripheral players. As a result, they have also become a potential platform for new and creative money laundering and sanctions evasion schemes, which have brought them under greater regulatory scrutiny. The challenge now is to put in place controls that are not only fit for purpose today but can keep pace and evolve with growing transaction volumes and new products while also being able to counter the new methods bad actors devise every day.

Sadie: If we define the fintech umbrella to include digital assets, stablecoins and crypto, there are clearly evolving regulatory expectations. In fact, news came out recently that the EU banking regulator designated USDC, a stablecoin, as its first significant e-money token, which is a major development for fintech organisations. The most significant compliance, governance and control changes come down to anticipating growth. Organisations need to ensure their compliance programmes, governance frameworks and controls are updated, adjusted and scaled appropriately as they expand and deploy technologies to support compliance functions in a way that is secure, tested and risk-managed. This is especially important as firms continue to introduce products like stablecoins and crypto, which remain major areas of focus and regulatory attention in the US. The challenge is making sure compliance capabilities evolve at the same pace as business growth and product innovation.

McCarthy: Fintech payments firms, in particular, are emerging players in this space. They have increasingly large customer bases and attractive products, ranging from digital assets to traditional fiat-based products. They cover the waterfront, and their growing customer bases show they are long-term players in financial services. Regulatory expectations remain the same, but with younger customers looking for lower levels of friction, controls and compliance disciplines may need to be applied differently. We continue to see know your customer challenges and pressures. What does it mean to know a customer who transacts lower amounts than at a traditional FI and interacts only through digital mediums? How can an organisation demonstrate that it knows its customer and applies requisite due diligence? And what controls, monitoring and oversight are needed when customers communicate with others on these platforms? Fintechs are bringing unique, dynamic products to market, and that is new for regulators and enforcement agencies.

Mendes: For fintechs, it is about being able to keep up with the changing landscape they are operating in and the changing market landscape as well. As things happen in the world, every FI and every organisation has to respond to those changes. And often, it is hard to keep up with that pace from a compliance programme perspective, as it is a large programme that has to be managed. Fintechs keeping up with the risks the company is facing in real time is often difficult for organisations to manage and keep up with.

“Compliance must be seen as part of doing the right thing, a licence to operate and a prerequisite for continued growth.”
— Ayse Duran

FW: To what degree has the focus shifted from documenting compliance requirements to demonstrating that controls are producing effective and measurable outcomes?

McCarthy: I have heard a number of regulators say: ‘show, do not tell’. Documented requirements can be presented, but regulators want to see how they actually work. They want to understand, touch and feel the outputs and outcomes of controls. This is a big focus for regulators and law enforcement. This is particularly important for newer entrants like fintechs. Traditional FIs have spent 25 to 30 years developing an understanding of the importance of documenting what needs to be done, who does what and when. Newer organisations are not always as fluent in these operational methods or in understanding that controls must be documented, not just executed, and how they are meant to work together. If it is not documented, the risk that execution falters is high. Documentation has always been important, but now it is about documenting and showing results that demonstrate a control is working as intended. Organisations cannot do just one.

Mendes: Documentation is always important. An organisation has to be able to document its thought process and explain why it has decided to go one way or the other. From what we have seen, there is a greater focus on actual outcomes. A great process may have been documented, but if that process is not delivering required results, then it is not going to get there. There is definitely a greater emphasis on what organisations are actually getting out of the programmes they are building, changing and advancing. Are risks being mitigating as anticipated? Are controls working as expected within the programme? Ultimately, outcomes are the measure of a successful programme.

Sadie: There will always be a focus on ensuring that the appropriate documentation is in place for the compliance programme, whether that includes frameworks, policies or standard operating procedures. Both regulators and fintechs want to ensure that controls are truly effective. In the fintech space, there is a strong push to better leverage technology to demonstrate that effectiveness. Fintechs take the view that applying technology can help create a compliance programme that delivers effective, cost-efficient and risk-based outcomes. Rather than focusing solely on documentation and manual processes, organisations are increasingly looking at how technology can strengthen controls, improve monitoring and provide greater evidence that compliance programmes are operating as intended.

Duran: Documentation is still an important hygiene factor. However, both regulators and companies have seen that what looks great on paper does not always produce the desired results when implemented. As a result, there is much greater emphasis on demonstrating effectiveness through pre-testing before launch, targeted pilots and phased rollouts. The focus has shifted from simply documenting controls to proving that they work and produce measurable outcomes. AI and data quality have also played a role in this shift. A lot of these programmes depend on high-quality, traceable data and strong data governance. While fintechs are often viewed as more data-native, our experience shows that technically robust solutions do not always deliver the most effective outcomes in compliance. Because of that, regulators are placing more emphasis on testing, reviews and evidence of sustainable results. I have definitely seen this become a much bigger focus over the last 18 months or so.

Walters: For a long time in the UK, the focus has been on producing effective and measurable outcomes. That holds true in the fintech arena as well. The focus is particularly on the compliance outcomes that firms achieve. What you often see in fintech is both poorly documented compliance and poor outcomes, so it is a bit of a double whammy. But those two issues are not necessarily mutually exclusive. In other words, poorly documented compliance requirements can sometimes go hand in hand with ineffective outcomes that are difficult to measure.

FW: When independent reviews uncover weaknesses, what are the most important factors in turning your remediation efforts into lasting organisational improvement for fintechs?

Sadie: A band-aid approach should be avoided. Rather, it is important to ensure that the root cause for the identified weakness is fully understood. Organisations should take a step back and ensure that holistic remediation of the root cause is uncovered – for example, in a situation where the finding states that standard operating procedures are not detailed enough to document how to deal with an issue, such as a politically exposed person, the ‘band-aid’ remediation is just adding more words to standard operating procedures. However, the appropriate way to evaluate whether the remediation is holistic is to obviously improve documentation, but also to ensure that the updated process is being enforced, training is rolled out and the process is being subjected to appropriate quality control functions. This will ensure that, after new procedures have been rolled out and trained, the application of those new procedures is properly executed.

Walters: In one significant remediation programme for an organisation that had been subject to a section 166 skilled-person review, at the end of the process, the regulator lifted the voluntary restriction that had been placed on the organisation. That created a tangible outcome, allowing the business to return to normal operations and resume growth. Several factors contributed to that success. First, there was a strong partnership between the parties involved. Second, rather than simply producing reports and assigning red, amber and green ratings, the process involved building the control environment, compliance programme and risk framework. There was also strong communication and transparency between the parties, with a shared desire to put the firm on sustainable footing so it could continue to support its growth trajectory.

McCarthy: A control weakness is rarely an isolated incident. There are both contributing and compensating factors, which is why a multidisciplinary, organisation-wide approach to remediation is so important. Legal, compliance, business, operations, technology, analytics and product teams all need to be part of the discussion, ownership, design, rollout and maintenance of new or enhanced controls. Where things fall down, it is often because a key constituency was not at the table or able to exercise the appropriate authority. That is why organisations need a fulsome team that spans the business. Larger organisations can also lean on external advisers, lawyers and consultants for lessons learned and insights into what has worked with regulators and in mitigating risk. There has got to be a balance, but those are levers that can and should be pulled, and they are often overlooked.

Mendes: When weaknesses are identified, fintechs sometimes try to respond quickly, but they really must get to the root of why something is happening to understand what changes need to be made. Do not be too quick to fix what is going wrong. Assess what is actually creating the problem. Has something changed in the business? Has something changed in the market? Maybe the systems that are being used or the controls that have been built are no longer responsive. Being able to understand the root cause is a critical element of effective remediation. Go back and figure out what happened, because there may be other things tied to it. It is not always possible to fix just one thing. The implications of making changes must be considered. Understanding why it happened, the changes that need to be made and the consequence of those changes in other areas is important.

Duran: From a transformation perspective, the organisations that ultimately win will not be the ones that simply ‘check the box’ and say they are compliant. Winners will be the ones that turn regulatory requirements into a competitive advantage and use them as a catalyst for transformation. To succeed, organisations need strong executive sponsorship and a cross-functional approach that brings together the business, compliance, technology and data teams. It cannot be a compliance-only exercise. It is also not about incremental improvements or patchwork fixes. The real opportunity is to rethink processes end to end. While ensuring compliance, organisations should also ask whether processes are efficient, where handoffs create friction, and how automation or advanced analytics can improve outcomes. Finally, everything starts and ends with people. Teams need the right tools, resources, governance and decision-making frameworks to act effectively. That is what creates lasting, organisation-wide change rather than a collection of siloed improvements.

“Fintechs are bringing unique, dynamic products to market, and that is new for regulators and enforcement agencies.”
— Andrew McCarthy

FW: How are fintech organisations balancing the need for robust compliance frameworks with commercial objectives such as growth, innovation and operational efficiency?

Mendes: Fintechs, by their nature, are meant to grow, be fast and be responsive. Compliance programmes are almost the opposite: precise, adaptable and scalable. The struggle is avoiding having a compliance programme that limits the ability to grow and be nimble. Simultaneously, organisations do want to build a programme that tests growth, challenges where they are going and what they are doing. It is not, ‘You want to do that? Let me build something that makes it harder’. Instead, it is, ‘You want to do that? Let us think through how we can make that happen and mitigate those risks as effectively as possible’, while also being able to say, ‘That just does not work for our organisation’. What is needed is a compliance programme that asks: is this the right thing to do? If yes, what steps do we need to take to protect not only our organisation, but the financial system as a whole?

Duran: The balancing act is real, and it is far from resolved. For years, compliance has been viewed as a checkbox exercise and, in some cases, a nuisance in an environment focused on innovation and growth. This is understandable as fintechs are built around speed, seamless customer interaction with minimal friction, and innovative solutions that challenge traditional players. As fintechs become more embedded in customers’ financial lives and offer increasingly complex products, regulatory expectations naturally increase. That is where the mindset shift needs to happen. Compliance must be seen as part of doing the right thing, a licence to operate and a prerequisite for continued growth. That does not mean fintechs need to operate exactly like banks. Rather, they need to build compliance into their workflows by design, so it becomes part of how they work, not an additional layer of bureaucracy. Given their strengths in data, automation and AI, they are often better positioned than most.

Walters: A former senior US law enforcement officer once memorably said: “If you think compliance is expensive, try non-compliance.” The mistake I often see with high-growth fintechs is a lack of upfront investment in getting the balance between compliance and growth right. The question is often framed as if compliance comes at the expense of innovation, but sustainable growth cannot be achieved without strong compliance. Regulators are aware of the risks posed by high-growth, low-compliance organisations. In the UK, for example, regulators can impose a voluntary requirement, which is about as voluntary as paying taxes. If they identify significant compliance weaknesses, they can restrict a firm from taking on new customers or processing certain transactions. For fintechs, this is extremely disruptive. That is why investing early in compliance frameworks is fully aligned with commercial objectives. Done right, compliance supports growth, innovation and operational efficiency rather than slowing them down.

Sadie: We are talking about what is sitting between the two sandwich loaves, and compliance is often stuck right in the middle. I think some fintech organisations struggle to balance the need for a robust compliance framework, which requires a certain level of investment, against the desire to grow, less customer friction and releasing new products. We have clients we jokingly call ‘overachievers’ because their growth ambitions sometimes outpace their compliance infrastructure. I often see a struggle between the business trying to grow too quickly and the compliance function not having the capacity, or sometimes the authority, to keep pace with what is required. Consequently, new products and features can be rolled out before they have been subjected to the appropriate risk assessments or before the necessary compliance controls have been implemented. The challenge is ensuring that growth and innovation happen in a way that remains aligned with regulatory requirements and compliance expectations.

McCarthy: Robust compliance and growth are not mutually exclusive. Compliance cannot be seen as a drag on the business. Yes, there is always going to be healthy tension between the drive to grow, roll out new products, and the controls and oversight necessary to mitigate risks. But organisations that are strongest with their customers also tend to be strongest in their compliance disciplines and frameworks. At the end of the day, much of financial services is built on trust. Does the customer trust the FI? That often comes down to whether it can prevent misuse of the platform for criminal or unethical activities. The stronger the compliance programme and controls, the stronger the business will be. Organisations that treat compliance as a cost centre eventually get tripped up. Regulators may intervene, fraud can erode revenues, and trust can be damaged. Ultimately, that hurts an organisation’s ability to win, maintain and grow customer relationships.

“Fintechs take the view that applying technology can help create a compliance programme that delivers effective, cost-efficient and risk-based outcomes.”
— Jaco Sadie

FW: In what ways are technologies such as AI, automation and advanced analytics changing the way fintechs’ compliance risks are identified, monitored and managed?

Duran: Fintechs are often the first to adopt AI and advanced analytics. They move quickly, hire top engineering talent and deploy capabilities at speed. What is sometimes missing is the domain expertise needed to guide those technologies and ensure they deliver the right outcomes. AI is being used beyond experimentation – from transaction monitoring and alert generation to case management and investigations. Therefore, there is growing interest from regulators to understand how firms are selecting AI use cases, what training data they are using, how models are governed and how they are tested before deployment. What I see is fintechs moving quickly, only to go back later and fill governance and control gaps, and that is concerning to many regulators. One challenge is that different regulators are at different stages of maturity in terms of developing their own approach to AI. In certain areas, there is a clear expectation that humans remain in the loop rather than relying on full automation, while in other areas the guidance is not fully in place yet.

Walters: There are huge productivity and risk management gains to be derived from AI in the compliance space. The trick is not to grasp defeat from the jaws of victory. In pursuing efficiency and risk management gains, organisations do not want to complicate matters so much that they inadvertently introduce compliance risk. Further complicating the issue is whether people are actually ready for this. Take the example of an organisation focused on its highly complex AI-driven customer risk assessment model. If the organisation is already concerned about how to explain the model to the eventual reviewer it is not a great sign. If a firm struggles to explain how its AI works, how decisions are made and how outcomes are validated, it becomes harder to demonstrate that the model is appropriately governed and producing the right results.

Sadie: I do not think there is a fintech company that is not thinking about, attempting or at least exploring the use of AI, automation and advanced analytics. When you talk to almost any fintech, that is going to be part of the conversation. I have seen this done well and also done poorly. This is going to be an area of focus for regulators. They will want to understand how AI is being used, whether there is appropriate governance around it, whether it has been properly tested and whether it is being effectively monitored. The Conference of State Bank Supervisors recently released guidance for state examiners on evaluating the deployment and governance of AI. I think fintechs can leverage and learn a lot from this guidance and apply those principles to how they manage and govern AI and automation. The key is making sure innovation is supported by strong governance, oversight and risk management.

Mendes: This is probably the most exciting time when it comes to identifying, managing and mitigating risks. The organisations that are using AI and analytics as part of their daily work are the ones getting ahead of those risks. Is AI hurting or helping organisations? The answer is both. It is helping fraudsters become better at scamming and perpetrating fraud, but FIs have more data available to them than fraudsters do. The difference is being able to use that data in a quicker, more comprehensive way. That said, if a programme has problems, implementing AI is just going to provide faster, bigger problems. The foundation has to be strong. Once it is, these tools can help identify trends, weaknesses, portfolio shifts, geographic changes and emerging transaction patterns, while mitigating them more effectively.

McCarthy: Beginning with big data, then machine learning and now agentic AI, I have seen a true sea change in how operations, not just compliance, can and should be performed. Threats can be identified and resolved more quickly, and the ability to pivot and calibrate controls in days rather than weeks or months is fantastic. The risk comes when organisations roll out these advanced technologies and analytics approaches without commensurate testing and challenge. Are they governed the right way? How are they ingesting information and learning without impairing compliance or creating other risks? Governance needs to be set up from minute one. For fintech and engineering-grounded organisations, moving quickly is part of the DNA and a huge strength. But there needs to be deliberate thinking around the risks and considerations in the design and rollout. As the SEAL teams say, ‘Slow is smooth, and smooth is fast’.

“AI is going to make fraudsters better at what they do, which means organisations will need to become much better at identifying, preventing and responding to fraudulent activity.”
— Stella M. Mendes

FW: Looking ahead, which developments are most likely to shape the future of monitorships, independent reviews and compliance transformation for fintechs over the next few years?

Mendes: AI is going to have the single greatest impact on the industry because it has so many implications. It is going to change how fintechs and FIs gather, use and protect their data. AI can be used against people and organisations so easily that I think it is going to increase organisations’ risk profiles by a pretty significant margin, in ways we have not seen in quite a while. As a result, FIs are really going to have to focus on weaknesses in their data, their systems and how they identify fraud. Fraud is probably the biggest area where we will see the impact of AI. AI is going to make fraudsters better at what they do, which means organisations will need to become much better at identifying, preventing and responding to fraudulent activity.

Duran: Regulators and supervisors are moving from general questions to very specific AI use cases. They are focusing on how AI is governed and monitored, how human intervention is incorporated and how fintechs ensure auditability. Regulatory questions and expectations around AI are becoming much more targeted. Along with that comes a greater focus on third-party management. If firms are relying on external resources rather than their internal teams, regulators want to understand how those relationships are managed. In Europe, with the EU AML package, we also expect more coordinated supervision. While the EU does not have a direct equivalent to skilled person reviews or monitorships, and approaches still depend on local legal frameworks, the trend is toward a more unified framework. I also think there is a growing emphasis on evidence-led reviews, demonstrating that controls are effective and sustainable, not just well-documented.

Walters: I remember a regulator once telling me when I worked at a bank, ‘I don’t care about your controls, I only care about the outcomes’. And I think that is really the key point. What shapes the future of these reviews and interventions will be how quickly the fintech sector grows and whether that growth occurs within a strong control framework or in a less controlled environment where the focus is on volume rather than outcomes for clients and customers. If it is the latter, we will see more monitorships, more section 166 skilled person reviews and greater use of tools like the voluntary requirements. Ultimately, the regulatory response reflects industry behaviour. When growth is well controlled, regulators tend to take a lighter-touch approach. When it is not, the level of intervention increases accordingly.

McCarthy: Threats, adversarial countries and transnational crime are all constantly evolving, and they will continue to shape the nature of the threat landscape and monitorships, in large part because of the sophisticated technology and analytic tools available to the bad actors nowadays. That means the way these historical typologies manifest themselves changes, but the underlying threats and risks remain. When we think about the developments that are going to shape it, it is the bad guys changing tack because the good guys have moved over here or over there. Organisations that become really adept at horizon scanning and distilling intelligence gleaned from their customers will be able to anticipate in a much more meaningful way. Ultimately, it is a function of the threats and how they are using technology to perpetrate the bad stuff.

Sadie: Usually, monitorships arise because something went wrong, and the regulator wants to ensure the remediation is completed appropriately. The appropriate deployment of technology, and especially AI, will very likely be one of the key areas both compliance officers and regulators will focus on. Similarly with independent assessments, although much attention is placed on policies and procedures, assessing the deployment of technology should become an integral part, and ‘check the box’ assessments will become insufficient. Interestingly, investors in fintechs view monitorship as a positive because it gives them confidence that the company would ultimately build a stronger, risk-based compliance programme. Most FIs see a monitorship as evidence that something went wrong, which is often true, but it can also provide assurance that the organisation will be better positioned going forward.

 

Stella Mendes leads FTI Consulting’s global financial services practice, focusing on financial institutions, bank governance and regulations. With more than 25 years of diverse banking industry experience, she leads anti-money laundering and Bank Secrecy Act reviews for banks, money service businesses, credit unions and other financial service providers. Ms Mendes has previously served as president and chief operating officer for First National Bank of NY and as the compliance & bank secrecy officer. She can be contacted on +1 (212) 841 9363 or by email: stella.mendes@fticonsulting.com.

Jaco Sadie is a senior managing director in the financial services practice based in San Francisco and co-leads the North American financial services practice. He is a senior business adviser with extensive experience providing anti-money laundering, sanctions and fraud advisory, forensic accounting, investigative and litigation services. Mr Sadie provides financial crime related compliance and investigative services to financial institutions and regulators, specialising in AML and sanctions compliance related projects. He can be contacted on +1 (415) 283 4230 or by email: jaco.sadie@fticonsulting.com.

Andrew McCarthy, co-leader of the North American financial services practice, has extensive experience with, and knowledge of, financial crime and general financial conduct regulations and guidelines from the US, UK, Singapore, Hong Kong and Australia. He has primarily advised financial services clients on AML, economic and trade sanctions, fraud, tax crime, and client suitability risks and related customer due diligence and transaction monitoring operating models and control transformations. Mr McCarthy also has significant experience leading and performing sensitive regulator or law enforcement imposed assessments and investigations. He can be contacted on +1 (571) 421 9304 or by email: andrew.mccarthy@fticonsulting.com.

Ayse Duran is a senior managing director in FTI’s business transformation practice, with more than 15 years’ experience in strategy, large-scale, multi-disciplined transformations, data and Al. She specialises in strategic transformations and regulatory-driven change and advises financial services institutions across EMEA and the US. Working with C-suite leaders at the intersection of transformation, compliance and data, she helps organisations navigate complex regulatory environments, identify growth opportunities, and redefine business and operating models. He can be contacted on +31 (6) 213 65730 or by email: ayse.duran@fticonsulting.com.

Mike Walters helps financial services clients navigate complex risk, financial crime and regulatory compliance issues. He is a former regulator and global bank chief compliance officer with significant compliance and financial crime experience. Previously, Mr Walters was the global head of compliance and financial crime for Barclays Bank. Before joining Barclays, he was a partner in a global consulting firm where he carried out section 166 reviews on governance, risk and conduct-related issues, focusing on banks and investment managers. He can be contacted on +44 (0)7769 977 947 or by email: mike.walters2@fticonsulting.com.

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