Largest Custody Bank - Case Study #2


Global financial services company with the world’s largest asset servicing business - Case Study #2

The Mandate

Draft high-level roadmap for the implementation of the FX Global Code.

Approach and Key Findings

In collaboration with Legal and Compliance, the Global Code was broken down into specific deliverable components, i.e. deliverables tracker, across all the Code Principles that would convert into a traceability matrix for the Federal Reserve, the client’s primary regulator. We then conducted a Gap Analysis phase that encompassed review of existing processes and associated documentation. There were also key stakeholder discussions to identify how much of the existing infrastructure met the requirements of the Code as detailed in the traceability matrix. The remaining components were then cataloged and categorized, e.g. policy, a procedure, with high-level requirements. This catalog of work was then mapped out over the subsequent 6 months to ensure compliance with the Code.


The client had a traceability matrix, i.e. deliverables and owner of the deliverable, that could be presented to the Federal Reserve and an inventory of missing components with high-level requirements for completion.


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