The problem: programmes that were on plan until they were not
A large remediation programme rarely announces its difficulty. The early phase often looks reassuring. Population sizing is signed off. Vendors are appointed. Reviewers are hired. Files move. The dashboard shows throughput. The problem becomes visible later, when quality begins to drift, rework grows, scope questions reappear and the MI no longer tells one coherent story.
That trajectory is not inevitable. But the weaknesses that produce it are usually visible much earlier than the programme admits.
The evidence: what remediation work tends to expose
Five failure modes I see repeatedly
Good practice and poor practice in remediation design
Business impact: the cost of drift
Programme drift is expensive because it compounds. Files processed against a weak standard create rework. Rework absorbs capacity that was meant to reduce the population. Governance then spends more time explaining the old problem while trying to fund the correction.
In the programmes I have worked on, the cost of fixing drift after it has embedded has been materially greater than the relatively unglamorous investment that would have prevented it: better scoping, clearer standards, stronger QA and more useful MI.
Practical actions
The Claritas approach
We are usually asked to help either before delivery scales or after the programme has begun to drift. The work is different in each case.
At the front end, I would test the population, scope, definition of completion, QA design, governance authority, capacity assumptions and MI before the plan is treated as settled.
Where a programme is already in difficulty, I start diagnostically. I compare what the programme says is complete with the operating evidence, test the assumptions underneath the plan, review the QA and governance record and identify the smallest number of changes needed to restore control.
That is diagnostic work unless Claritas has explicitly been commissioned to provide Independent Assurance.
In either case the deliverable is short. Programmes rarely fail for lack of paper. They fail when the important questions about scope, quality, capacity, risk and ownership remain unresolved until delivery pressure forces an answer.
- 01A written definition of completion exists and is understood consistently across delivery and QA, with material judgement differences explainable through methodology and evidence.
- 02QA results are interpreted with the sample, defect themes, severity and calibration context rather than reduced to one pass-rate or divergence number.
- 03Programme MI shows activity, quality, population and residual risk together, and material changes are explained.
- 04Governance authority is clear. Material scope changes, exceptions, escalation and completion decisions can be traced to the appropriate owner and supporting evidence.
- 05Where additional challenge or assurance is required, the firm is clear whether it is using second-line challenge, Internal Audit, Independent Assurance or external diagnostic review, and what question that work is intended to answer.
- Financial Conduct Authority, Final Notice: Starling Bank Limited, October 2024 (financial crime controls that did not keep pace with growth, sanctions screening deficiencies, breach of the voluntary requirement and subsequent remediation).
- Central Bank of Ireland, enforcement action against Coinbase Europe Limited, announced November 2025 and confirmed in the High Court in 2026.
- Regulation (EU) 2024/1624 (AMLR), customer due diligence and record-keeping requirements relevant to remediation completion standards.
- SEPBLAC, published guidance and annual reporting on ongoing due diligence expectations.
