VIRTICUSRequest Assessment

About Virticus

A specialist team. Independent by design.

Virticus was built for FCA-regulated firms that have to defend their fraud and AML detection rules: environments where automated decisions create real risk for customers, the business, and its standing with the regulator. The proposition is deliberately narrow and senior-led.

Virticus is built on years of writing and tuning fraud and financial-crime detection rules inside major UK banks and payment environments — a discipline shared across the team — with a broader background explaining models and decisions under regulatory scrutiny. The purpose is simple: to make fraud and AML rules documented, accountable, and defensible by design, rather than a black box.

Operating Profile

Independence

No stake in the system under review.

Senior-led

Direct engagement from first briefing to final output.

Evidence-based

Findings anchored to what the system did, not what it claimed.

Confidential

Handled with business and legal sensitivity.

Advisory Positioning

Fraud Rule DefensibilityAMLFinancial CrimeAI GovernanceExpert Witness

Background

Inside knowledge of accountability under pressure

The common thread is not sector branding. It is exposure: systems operating where outputs matter, evidence matters, and explanations matter. That discipline was honed writing fraud and financial-crime rules in banking — and it is what Virticus now brings to FCA-regulated firms that lack an in-house model-risk function.

Sector 01

Financial Crime (Flagship)

Writing and tuning fraud and AML detection rules at scale across banking and payment environments — APP scams, transaction monitoring, card, and application/mule fraud. Rules had to be written at pace, perform under pressure, and be defended when challenged: documented rationale, tested thresholds, traceability, and decision control, not detection performance alone.

Sector 02

Banking & Financial Services

Interest calculation models, driver-based financial models, and Buy Now Pay Later balance logic where errors created financial and regulatory exposure. The risk was not only model failure, but misplaced confidence in outputs affecting customer balances, management decisions, and regulatory standing.

Sector 03

Government & Public Sector

Data systems supporting urgent central government decisions during the COVID-19 period, where information had to be reliable, explainable, and timely under exceptional pressure. Errors in underlying data directly affected public decisions and formal reporting.

Sector 04

Public Health

Analytical and operational tooling at a national public health body, where outputs supported policy-shaping evidence chains and reporting at population scale. The challenge was maintaining control and accountability while systems were used at pace under scrutiny.

Sector 05

Education

AI tools used to generate student feedback, support marking activity, and personalise learning pathways. The risk was consistency, fairness, and the difficulty of defending outputs that reached students without adequate review.

Sector 06

Accounting & Professional Services

AI automation in bookkeeping and submission preparation, where small classification errors or unsupported assumptions could flow through into financial and tax outputs. Validation controls were needed before outputs reached formal reporting stages.

Sector 07

Transactions

Transaction environments where data quality, consistency, and explainability were under commercial and investor scrutiny. Information supporting value and performance needed to withstand close external challenge during a sale process.

Differentiators

What sets the work apart

Focus 1

Technical depth

The analysis follows data flows, model behaviour, decision gates, and control records rather than stopping at policy language.

Focus 2

Operational realism

The advice draws on systems that have already operated under regulatory scrutiny, public accountability, and real legal pressure, and translates that experience into practical decisions for smaller firms.

Focus 3

Senior delivery

Clients work directly with specialists, not a tiered delivery team or a generic consulting process.

Method

The same operating sequence, every time

Scope, examine, analyse, report. The brief may change, but the method is stable: understand the system, trace the evidence, and make the findings usable.

01

Scope

System, context, accountable audience, and decision pressure.

02

Examine

Data, model, controls, outputs, and where the record is weak.

03

Analyse

Independent technical judgement against the evidence.

04

Report

Clear findings for owners, senior managers, legal advisers, or any formal inquiry.

Get in touch

If you have to defend your fraud and AML rules, start here

Virticus works with FCA-regulated firms that need to understand where their detection rules are exposed, improve coverage and control, or defend their rules when challenged. A short discussion is usually enough to determine what is needed.