Temporary Permissions Regime for Brexit And Outsourced Compliance and Risk Resources
The Client’s Needs
The client, the UK Branch of a large German insurer had applied to the PRA to enter the Temporary Permissions Regime for Brexit. Recognising that PRA and FCA authorisation was going to require significant changes in the control environment for the branch ICSR were asked to provide advice on their obligations during the TPR and thereafter once a fully authorised Third Country Branch.
Subsequently the client also requested ICSR to provide support by way of outsourced compliance and risk resource to assist them to undertake control reviews and support the building of their control environment.
ICSR provided advice on the requirements of the TPR, the obligations applying to the Branch and the regulatory requirements and expectations for the Branch with regard to governance, risk and compliance frameworks which would need to be enhanced to change from an EU Right of Establish Branch to a Third Country Branch at the time the Brexit Transition period expired.
Subsequently, ICSR assisted with risk and compliance control testing as the Branch developed its’ Frameworks.
ICSR deployed a team of resources including experienced risk and compliance professionals to assist the insurer.
The client was able to plan the development of its corporate governance and risk, compliance and control framework in order to meet PRA and FCA requirements under the TPR and thereafter.