Defensibility Deliverables
Proof the controls would stand up to scrutiny
We deliver something concrete: the same three artefacts every time — a defensibility scorecard, a coverage map, and a regulator-ready documentation pack, with each control mapped to the regulation it implements. Built the same way every time, so they read the same under challenge as they did the day we handed them over. We start with fraud and AML rules, where the PSR’s mandatory APP-fraud reimbursement makes defensibility a board-level question.
Our Approach
We diagnose and document. The fix stays with you.
We start with the rules and controls already in place, score how defensible each one is, and show where coverage is missing.
The output is evidence to hand a regulator, the Financial Ombudsman, or a court: what each control does, why it is justified, and which obligation it implements. The engine builds it the same way every time — reproducible and open to inspection.
The Three Deliverables
Defensibility scorecard
DiagnoseA rating for each rule or control: how well it would hold up if challenged
Coverage map
MapWhere controls are strong, thin, or missing across the live estate
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
Score each rule, map the coverage, map it to the regulation
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 the size of the estate and the regulations that apply.
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 handed to automated and AI systems.
01
Fraud & AML rules — flagship
Scope
- Review the 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
What is different about this
Every decision can be traced back to why it was made
Defensibility built in across all four financial-crime domains, for UK FCA-regulated firms that must evidence every decision.
Reasoned, every time
It reasons 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.
The firm keeps the cure
We diagnose the gaps and document the controls; the rules, rationale, and evidence stay in-house to run and defend.
Get started
See where the fraud rules stand
Answer a short set of questions about the fraud and AML rules. The result is an early read on how defensible they are and where the coverage gaps sit.