Defensibility Deliverables
Proof your controls would stand up to scrutiny
Every engagement produces the same three artefacts: a defensibility scorecard, a coverage map, and a regulator-ready documentation pack — with each control mapped to the regulation it implements. We start with fraud and AML rules, where the PSR’s mandatory APP-fraud reimbursement makes defensibility a board-level question.
Our Approach
Diagnose, document, keep the cure.
We do not start with generic compliance language or oversized frameworks. We start with the rules and controls you already run, score how defensible each one is, and show where coverage is missing.
The output is evidence you can hand to a regulator, the Financial Ombudsman, or a court: what each control does, why it is justified, and which obligation it implements. It is built consistently, not from a black box.
The Three Deliverables
Defensibility scorecard
DiagnoseA rating for each rule or control: how well it would hold up if challenged
Coverage map
MapWhere your controls are strong, thin, or missing across the risks you face
Documentation pack
DocumentRegulator-ready evidence, each control mapped to the regulation it implements
Consistent by design
Every pack is produced the same rigorous way — repeatable, traceable, and explainable line by line.
Assessment
How we build your defensibility evidence
Step 1
Score each rule
Step 2
Map the coverage
Step 3
Map to regulation
Each control
The obligation it implements
Each gap
The exposure it creates
Each pack
Regulator-ready evidence
We adjust the depth to your size and the regulations you fall under.
Where It Applies
The same deliverables, two domains
Fraud and AML rules are the flagship. The same scorecard, coverage map, and documentation pack also stand behind the decisions a firm lets automated and AI systems make on its behalf.
01
Fraud & AML rules — flagship
Scope
- Review your live fraud and AML rule set
- Score each rule for defensibility
- Map coverage against APP-fraud and AML risk
Output
- Rule defensibility scorecard
- Coverage map
- Documentation pack
- Regulation mapping
02
PSR APP-fraud readiness
Scope
- Test rules against reimbursement scenarios
- Identify thin or unjustified thresholds
- Evidence proportionality of each control
Output
- Reimbursement-scenario review
- Gap and exposure summary
- Defensible rationale per rule
- Ombudsman-ready evidence
03
AI governance — secondary
Scope
- Map decisions made by automated or AI systems
- Score how defensible each decision is
- Define and document the controls around it
Output
- Decision register
- Defensibility scorecard
- Documented controls
- Regulation mapping
04
Independent assurance
Scope
- Support internal risk and compliance teams
- Validate existing rules and controls
- Provide independent, repeatable analysis
Output
- Assurance report
- Control validation
- Expert review
- Litigation support
Differentiators
Defensible by design, not a black box
Built by specialists in fraud rule-writing across all four financial-crime domains, for UK FCA-regulated firms that must evidence every decision.
Reasoned, not generated
We reason the same way every time, so every score and every line of the pack can be traced and explained — the standard a court or ombudsman expects.
Mapped to regulation
Each control is tied to the obligation it implements, so the documentation pack reads as evidence rather than as a generic policy.
You keep the cure
We diagnose the gaps and document the controls; the rules, rationale, and evidence stay with your firm to run and defend.
Get started
See where your fraud rules stand
Answer a short set of questions about your fraud and AML rules. You will get an early read on how defensible they are and where the coverage gaps sit.