The FCA required the firm to demonstrate that it could sustain critical front-office functions — including trading and fund management — during severe IT outages to mitigate severe damage to itself, its clients and the wider market due to the size of fixed income holdings. The existing contingency arrangements were not capable of surviving an anti-ransomware attack or similar threat — I led an industry first solution.
A new standard for operational resilience: teams across the business had to identify their most important business services, set impact tolerances, and demonstrate they could remain within those tolerances during disruption. For a front-office investment manager, the ability to execute trades and manage fund positions during an IT outage was a critical business service — and the existing contingency arrangements did not meet the required standard.
The programme needed to design and deliver a solution that would satisfy the regulator, protect the firm's ability to manage risk during an outage, and be operationally viable for the front office in a real crisis scenario.