Perspectives
Perspective 017Programme Scoping

Programmes do not fail because they were too ambitious. They fail because their assumptions were never tested.

A practitioner's note on what scoping really is: the discipline of refusing to write a number down until you can show your working, and the register that holds the plan together when the numbers start to move.

By Everett MorganEarly Autumn 20268 min read
Stacked customer files on a quiet office desk under low evening light
Executive summary

Programmes rarely fail because they were too ambitious. They fail because the numbers underneath the ambition were never tested before the Steering Committee approved them.

This is a companion note to Guide 009, Scoping an AML Remediation Programme. The guide sets out the full scoping cycle, decision by decision. This piece sits on the single most useful artefact I produce in a scoping, and the discipline that makes the artefact worth having.

Key takeaways
  1. 01

    Programmes I am asked to recover are rarely too ambitious. The recurring problem has been the same: the ambition was priced against numbers nobody had properly tested. The volume came from a single query. The productivity came from a benchmark. The capacity was divided out of the productivity without a working week underneath it.

  2. 02

    Scoping is mostly the discipline of refusing to write a number down until you can show your working. The team will resist this in week one. The Steering Committee will resist it more. The two weeks spent insisting on a reconciled population, a representative pilot on real files and a capacity model built in layers are the two weeks that tell you whether delivery is starting from evidence or optimism.

  3. 03

    The single most useful artefact I produce in any scoping is the assumptions register. Not the plan, not the budget, not the slides. The register. Every material assumption the plan depends on, with its basis, its named owner and the trigger at which it gets re-tested.

  4. 04

    I normally rebuild the register three times before mobilisation: after the population work, after the pilot, and before final mobilisation approval. Each rebuild changes something, and anything material goes to the Committee against thresholds agreed at mobilisation.

  5. 05

    I have found programmes much easier to recover when the assumptions are still visible and somebody owns them. The real trouble starts when changes have been absorbed quietly for months and everyone is still pretending the original plan is the plan.

  6. 06

    If your scoping paper does not have an assumptions register attached, the paper is not finished. It is a draft for a paper that has not yet done the work it needs to do.

I have been asked, more than once, to recover programmes that were described, when I arrived, as too ambitious. That has almost never been the problem. In the programmes I have been asked to recover, the recurring problem has been the same: the ambition was priced against numbers nobody had properly tested.

The volume number had come from a single query against a production database, run by one person, against a cut-off that was never reconciled. The productivity number had been lifted from a benchmark slide that nobody could trace to a particular firm or a particular type of file. The capacity number had been divided out of the productivity number without a working week underneath it: no allowance for QA, no ramp-up, no attrition, no leave. The plan looked precise. None of the numbers were robust.

And there is another part people sometimes miss. Cleaning up the old population only gets you so far if the BAU control that created it is still producing the same problem. You have to scope the historical repair and the control change that stops you building the next backlog.

What scoping actually is

Scoping is mostly the discipline of refusing to write a number down until you can show your working. The team will resist this in the first week. The Steering Committee will resist it more. There is always a date by which the plan has to be tabled, and the temptation to fill the gaps with a benchmark or an estimate is enormous.

The two weeks spent insisting on a reconciled population, a representative pilot on real files and a capacity model built in layers are the two weeks that tell you whether delivery is starting from evidence or optimism. They are also the weeks the Programme Sponsor is most likely to argue against. The argument is usually some version of: we need to start the work. The honest answer is that the work cannot start until the numbers it is sized against are numbers somebody is willing to defend.

The artefact that holds the plan together

The single most useful artefact I produce in any scoping is the assumptions register. Not the plan, not the budget, not the slides. The register. Every number the programme depends on, with the basis on which it was derived, the named owner who derived it, and the trigger at which it must be re-tested.

By the time the Committee approves the plan, the assumptions register has more entries than the budget has lines. That is the right shape.

I normally rebuild the register three times before mobilisation. Once at the end of the population work. Once at the end of the pilot. Once at the end of the mobilisation phase, the week before the Committee approves the plan. Each rebuild changes something. Sometimes the movement is small. Sometimes it changes the plan. The important thing is that it is visible in the register, and anything material gets to the Committee against thresholds agreed at mobilisation. The plan that goes forward should be the one built around what we now know, not the version everyone liked in week three.

Why the register matters in month four

Some of the numbers will move. That is not the problem. The problem is finding out too late, after the budget, team and deadline have all been built around the old ones. The question is whether they move inside a register the Committee can see, or outside a register that does not exist. I have found programmes much easier to recover when the assumptions are still visible and somebody owns them. The real trouble starts when changes have been absorbed quietly for months and everyone is still pretending the original plan is the plan.

The two versions of the programme had the same ambition at the start. Only one of them did the scoping work to make the ambition deliverable. The other ran on assumptions that were never tested, and on a Steering Committee that did not see the assumptions move because the register did not exist to hold them.

What I would do this week, if I were the Programme Sponsor

Open the latest scoping paper. Look for the assumptions register. If it is not there, ask the Programme Director for it, in writing, before the next Committee. If the register is there, look at the column for the named owner of each assumption. If the owners are missing, the register is a document, not a working artefact. If the owners are named, look at the trigger column. If the triggers are missing, the register is unlikely to be re-tested once the work begins. If the triggers are there, and the material ones carry a threshold at which they come back to the Committee, the register is doing its job.

Guide 009 sets out the full scoping cycle, including the independently validated and reconciled population, the file standard, the representative pilot on real files, the capacity model in layers, the correction of the underlying BAU control and the contingency conversation I would want the Committee having at mobilisation rather than at month six. Download the full guide and use the assumptions register at Appendix A as the starting point for your own.

About the author
Everett Morgan
Founder & Principal Adviser, Claritas Risk Advisory

Everett has more than twenty years' experience in financial crime, AML governance, regulatory compliance and operational risk gained within Deutsche Bank, Morgan Stanley and BNP Paribas. He established Claritas Risk Advisory to provide smaller regulated financial institutions with experienced independent judgement, practical insight and proportionate recommendations.

Need an independent perspective?

Preparing for regulatory change starts with understanding where your organisation stands today.

If you would like to discuss your financial crime framework or explore how Claritas Risk Advisory can help, I would be pleased to arrange a confidential conversation.

Let's start with a conversation