Clearhaven supports fintechs, payment firms and crypto-asset service providers through regulatory investigations, supervisory reviews, skilled person reviews and complex remediation programmes.

We help management understand what happened, respond credibly and deliver changes that can be supported by clear evidence.

When regulatory scrutiny increases

Regulatory attention can begin with an information request, a supervisory review, a whistleblowing allegation or a concern raised by an auditor, banking partner or board member.

The issue can escalate quickly if the response is incomplete, inconsistent or unsupported by evidence.

We help firms establish:

• What the regulator is concerned about

• Which products, customers and periods may be affected

• What information needs to be preserved and reviewed

• Whether the issue is isolated or systemic

• Which controls failed and why

• What the board needs to know

• How the firm should respond

• What remediation is likely to be required

The work is structured around the regulator’s questions, the firm’s wider exposure and the decisions management needs to make.

Regulatory investigation support

Clearhaven can support an investigation from the first regulatory request through to findings, remediation and closure.

Our work can include:

• Initial assessment and regulatory response strategy

• Investigation governance and reporting

• Document and data review

• Management and employee interviews

• Event chronologies

• Root-cause analysis

• Customer and transaction population analysis

• Assessment of control failures

• Regulatory response drafting

• Board and committee reporting

• Management interview preparation

• Regulator meeting support

• Remediation planning

• Coordination with legal counsel and other advisers

Where potential misconduct or enforcement action is involved, we work closely with the firm’s lawyers so that the regulatory, legal and evidential workstreams remain aligned.

Investigations involving fintech and payments

Fintech investigations often begin when rapid growth exposes weaknesses in systems, governance or operational capacity.

We support matters involving:

• AML and financial crime controls

• Customer onboarding and KYC

• Sanctions and PEP screening

• Transaction monitoring

• Fraud and scam prevention

• Safeguarding and reconciliation

• Consumer Duty and customer outcomes

• Complaints and customer treatment

• Regulatory permissions and perimeter issues

• Financial promotions

• Regulatory reporting

• Outsourcing and third-party arrangements

• Operational resilience

• Governance and management accountability

• Agent and distributor oversight

We examine the customer journey, funds flow, decision-making and control evidence to establish how the issue arose and how far it extends.

Investigations involving crypto and digital assets

Crypto investigations may involve transactions, wallets, entities and customers across several jurisdictions.

Our specialists understand the regulatory and technical questions that arise across crypto exchanges, custodians, brokers, trading platforms, wallet providers and other digital asset businesses.

Our work can cover:

• MiCA and CASP compliance

• UK cryptoasset regulation

• AML and sanctions controls

• Blockchain analytics and wallet screening

• Crypto transaction monitoring

• Source of funds and source of wealth

• Travel Rule compliance

• Custody and client asset protection

• Token and asset onboarding

• Market abuse and suspicious trading

• Conflicts of interest

• Cross-border services

• Staking, lending and borrowing

• Financial promotions

• ICT risk and DORA

• Regulatory reporting and record keeping

Where necessary, blockchain data can be combined with customer, transaction and operational records to develop a more complete picture of the activity under review.

Skilled person and Section 166 review support

A skilled person review can place significant demands on management and compliance teams.

We help firms prepare for and respond to Section 166 reviews, including:

• Readiness assessments

• Review scope analysis

• Document and data preparation

• Governance and project management

• Management interview preparation

• Quality review of submissions

• Response to information requests

• Findings analysis

• Remediation programme design

• Progress reporting

• Closure and validation preparation

We can also support firms responding to independent reviews commissioned by boards, regulators, auditors or banking partners.

Voluntary requirements and business restrictions

A voluntary requirement or regulatory restriction can affect customer onboarding, product launches, transaction volumes or the services a firm is permitted to provide.

Clearhaven can help management understand the operational effect of the restriction, establish the required governance and build a remediation plan around the conditions for release.

This can include:

• Analysis of the requirement and affected activities

• Customer and transaction controls

• Restriction monitoring

• Board and regulator reporting

• Remediation milestones

• Evidence collection

• Independent testing coordination

• Exit and closure planning

The programme remains focused on the specific regulatory concerns that led to the restriction.

Regulatory remediation

A credible remediation programme addresses the cause of the problem, the customers or transactions affected and the weaknesses that allowed it to continue.

We support the full remediation lifecycle:

• Findings and root-cause analysis

• Risk and impact assessment

• Target control design

• Remediation planning

• Programme governance

• Workstream management

• Policy and procedure changes

• Technology and data requirements

• Customer or transaction lookbacks

• Backlog remediation

• Staff and resource planning

• Training and implementation

• Control testing

• Management information

• Board and regulator reporting

• Closure evidence

• Post-implementation review

Each action is linked to a finding, an owner, a deadline and the evidence needed to demonstrate completion.

Financial crime remediation

Financial crime remediation often requires changes across data, systems, processes and teams.

We help firms address weaknesses in:

• Business-wide financial crime risk assessments

• Customer risk-rating models

• KYC and due diligence records

• Enhanced due diligence

• PEP and sanctions screening

• Transaction monitoring coverage

• Blockchain analytics

• Alert investigation and escalation

• Suspicious activity reporting

• Quality assurance

• Financial crime governance

• MLRO reporting

• Policies, procedures and training

We can also design and manage customer file reviews, transaction lookbacks and alert remediation programmes.

Customer and transaction lookbacks

Where a control has failed, the firm may need to establish which customers or transactions were affected.

We help define the population, review methodology, decision criteria, quality controls and reporting required for a defensible lookback.

This may involve:

• Customer file remediation

• KYC and CDD refreshes

• High-risk customer reviews

• Sanctions and PEP rescreening

• Transaction monitoring back-testing

• Historical alert reviews

• Blockchain transaction analysis

• Suspicious activity assessments

• Customer outcome reviews

• Redress population analysis

The approach is proportionate to the risk and supported by a documented methodology.

Independent validation and closure

Completed actions still need to be tested.

We assess whether new controls have been implemented, whether they operate effectively and whether the evidence supports closure of the original finding.

Validation can include:

• Design effectiveness testing

• Operating effectiveness testing

• Sample-based file and transaction reviews

• Data quality assessment

• Governance and reporting review

• Staff interviews

• Closure report preparation

• Follow-up recommendations

Where formal independence is required, remediation delivery and validation responsibilities are kept separate.

How we work

Stabilise the response

We establish governance, preserve relevant information and agree immediate priorities with senior management and legal counsel.

Establish the facts

We review documents, data, decisions and control evidence to determine what happened and how far the issue extends.

Assess the exposure

We consider regulatory, financial crime, operational and customer implications.

Respond clearly

We help management prepare accurate submissions, board papers and regulator communications.

Deliver the remediation

Findings are converted into a structured programme with accountable owners, realistic milestones and defined evidence requirements.

Prepare for closure

Controls are tested and the firm’s evidence is organised so that progress can be demonstrated to the board, regulator or independent reviewer.

Investigation experience that matters

Our work is led by practitioners with more than 20 years of experience across regulation, industry and consulting.

The team includes former leaders of regulatory units, Heads of Compliance, MLROs and senior consulting partners. Their experience includes leading more than 100 supervisory reviews, supporting skilled person and monitor-led reviews, conducting complex financial crime investigations and delivering regulatory remediation programmes across several jurisdictions.

We understand how regulators investigate, how firms respond and what a remediation programme needs to demonstrate before an issue can be closed.

Respond with control and credibility

Tell us what has happened, what the regulator has requested and where the immediate pressure sits. We will help you establish the facts and define the next steps.