Consumer Duty and customer outcomes
The FCA expects payment and e-money firms to show fair outcomes across products, pricing, communications and support, with particular attention on vulnerable customers and a board that can evidence it.
Compliance consulting for regulated firms
How do regulated firms grow while the FCA and other regulators keep raising the bar?
All Out Consulting gives firms – payment institutions, e-money institutions, FinTechs, and insurance brokers – senior, hands-on compliance support: Consumer Duty, AML and financial crime, compliance monitoring and regulatory change. It's delivered by a practitioner who has built and run these frameworks inside regulated firms, not just reviewed them.
- 20+ yearsin regulated financial services
- UK & EEAframeworks designed and run, FCA and DNB
- Deputy MLROexperience, including SAR decisions to the NCA
- NominatedWomen in Payments Awards 2026, Unsung Heroine
Regulatory pressures
The issues firms are dealing with now
Supervisors want evidence that controls work in practice, not just policies that say they should. These are the areas where firms most often need an experienced pair of hands.
Financial crime and AML/CTF
Firm-wide risk assessments, customer and business due diligence, transaction monitoring, sanctions screening and SAR decisions all need to be risk-based, documented and demonstrably effective.
Risk management and audit
Growing firms need a risk framework that gives the board a real view of the business, and internal audit that independently tests whether controls work before external auditors or the regulator do.
A payments rulebook being rewritten
HM Treasury is modernising the Payment Services and Electronic Money Regulations, the PSR is being folded into the FCA, and the EU is finalising PSD3 and the Payment Services Regulation.
Monitoring and assurance
A risk-based compliance monitoring programme, proper QA testing and clear reporting are what turn "we think we're compliant" into evidence for auditors, boards and the regulator.
Complaints and customer harm
Complaint handling, root-cause analysis and quality assurance are central to Consumer Duty, and complaints data for payment and e-money firms is coming under closer scrutiny.
How I help
Practical compliance support, sized to your firm
From a one-off gap analysis to regular monthly support, the aim is always the same: controls that work, evidence that holds up, and a team that understands why.
Consumer Duty
Implementation, outcomes monitoring and MI, fair value, vulnerable customers and support for the annual board assessment.
Find out more →Financial crime and AML/CTF
AML frameworks, firm-wide risk assessments, KYC/KYB, transaction monitoring and sanctions QA, SAR governance and MLRO support.
Find out more →Compliance monitoring and QA
Risk-based compliance monitoring programmes, control and QA testing, complaints QA and audit readiness across UK and EEA entities.
Find out more →Enterprise risk and internal audit
Enterprise risk management frameworks and registers, board risk reporting, and risk-based internal audits with findings tracked to closure.
Find out more →Regulatory horizon scanning
Daily scanning of UK and EU sources with a clear view of what each change means for a PI or EMI, when it applies and what to do.
Find out more →FCA application support
Preparing and assembling the compliance documentation for a new firm's FCA application: policies, procedures, monitoring plan and governance.
Find out more →Insurance brokers and intermediaries
SM&CR, adviser management and training and competence, oversight of the insurance advice process, ICOBS and Consumer Duty, drawing on seven years leading group compliance for an insurance intermediary group.
Insurance support →
Who I work with
Built for regulated firms, informed by the wider market
- Payment institutions and e-money institutions, including acquirers, card issuers and payment service providers with UK and EEA entities
- FinTech and payments start-ups building their first compliance framework or preparing an FCA application
- Growing firms whose compliance set-up needs to scale with new products, markets and partners
- Insurance brokers and intermediaries, including adviser networks and appointed representatives. See insurance support
- Boards and senior managers who want an independent, practical view before the regulator or auditors take one
Working together
What an engagement looks like
01
When firms get in touch
Usually when an audit or supervisory visit is coming, a framework needs building or rebuilding, Consumer Duty evidence feels thin, financial crime controls need testing, or the compliance team simply needs senior capacity for a while.
02
How the work runs
A short, focused look at your obligations, risks and current controls, then an agreed plan: a fixed-scope project, or a set number of days each month. You deal with me directly from start to finish.
03
What you receive
Gap analyses and remediation plans, frameworks, policies and procedures, monitoring programmes and test results, board and committee reports, training, and horizon scanning briefings you can act on.
Horizon scanning
Know what's coming, and what it means for you
Every day, dozens of UK and EU sources are scanned, led by the FCA and including the PSR, HM Treasury, the Bank of England, OFSI, JMLSG, the EBA, BIBA and the CII. Each relevant publication is broken down for payment and e-money institutions and insurance intermediaries:
- What kind of document it is, and why it's being done
- How it applies to a PI, EMI or insurance intermediary
- When it comes into force, and the deadline to comply
- Immediate actions and longer-term changes
HM Treasury consults on modernising the UK payment services framework
Comes into force
No date set
Respond by
6 Oct 2026
- Type: HM Treasury consultation
- Why: update the PSRs 2017 and EMRs 2011 for open banking, tokenised and AI-initiated payments
- PI/EMI impact: direct, covering authorisation, perimeter and conduct
- Now: gap-map your permissions and respond
- Later: implement the new FCA rules as they are finalised
FAQs
Questions firms often ask
Do you work with small or newly authorised firms?
Yes. A lot of the value is in helping smaller and growing firms put proportionate, workable controls in place. Controls should fit your size and risk, and hold up when you grow.
Can you help with Consumer Duty evidence for our board?
Yes. I led Consumer Duty implementation end to end at a regulated payments firm, including the outcome monitoring, MI and governance that feed the board's annual assessment. I can review what you have, fill the gaps and help you present it.
Can you support our MLRO?
Yes. I have Deputy MLRO experience across several firms, including reviewing internal SARs, deciding on external SAR submissions to the NCA, and owning the firm-wide risk assessment with board reporting. I can support your MLRO with reviews, QA, documentation and training.
Do you help new firms apply to the FCA?
Yes. I can prepare and assemble the compliance side of your application: policies and procedures, the financial crime framework, the compliance monitoring plan, governance and SM&CR documentation, so the submission is complete and consistent.
How do you charge?
Either a fixed price for a defined piece of work, or an agreed number of days each month for ongoing support. Everything is agreed in writing before work starts, so there are no surprises.
Do you work with insurance brokers and intermediaries?
Yes. I spent seven years as Head of Group Compliance for an insurance and mortgage intermediary group, overseeing 160 self-employed advisers, and I support brokers with SM&CR, training and competence, advice file checks and Consumer Duty. More on insurance support.
Where are you based?
In Wales. I work remotely with firms across the UK and Europe, and can be on site by arrangement.
Need an experienced compliance hand?
Tell me what you're working on. An initial conversation is free and there's no obligation.