Topic hub
Governance and Decision Defensibility
Boards and executive teams are increasingly expected to show their working, not just their conclusions. When a decision is challenged after the fact, what matters is whether the reasoning, evidence and dissent were properly recorded and tested at the time, not simply whether the outcome was reasonable.
Polar Insight's view
Polar Insight helps leadership teams build decisions that can withstand scrutiny before it happens, by testing evidence quality, capturing genuine challenge, and creating a rationale that holds up under review.
Featured insights
RTGS delay: why the CHAPS standards slip is a governance problem, not a technical one
The Bank of England has deferred the November 2026 RTGS standards release in its entirety after Swift postponed its own CBPR+ release, citing industry concerns about readiness for the removal of unstructured postal addresses. For boards that had budgeted, staffed and sequenced ISO 20022 migration around a fixed November date, the reset is a live test of change governance and vendor accountability.
Dolfin visa scheme: what the £35.5m ban says about SMCR integrity tests
The FCA has fined and banned former Dolfin executives over a scheme that helped at least 99 clients bypass investor visa rules, generating £35.5m in fees. The case resets expectations on shadow control, concealment, and senior manager integrity for boards across wealth and private banking.
SVS ban: FCA sends pension custody warning to fund manager boards
The FCA has fined and banned Demetrios Hadjigeorgiou, former CEO of SVS Securities, for failing to manage the firm and protect customers whose pension savings were placed in high-risk products. For senior leaders in asset and wealth management, the case sharpens personal accountability where retail money, product incentives, and pricing decisions intersect.
Debt management ban shows FCA tightening the honesty net
The FCA has banned Howard Roland Duckett, a former senior manager at debt management firm Beauforce Corporation, citing a serious lack of honesty and integrity following a High Court director disqualification he failed to disclose. Combined with the recent Blue Horizon prohibitions, the action signals a sharper regulatory posture on individual accountability that senior leaders and boards must factor into governance and disclosure practices.
Blue Horizon bans: the FCA draws a hard line on integrity at the top
The FCA has fined and banned two former Blue Horizon Asset Management executives for falsifying documents during attempted acquisitions of a UK bank and Reading Football Club. The case sets a clear marker on senior manager conduct and the evidentiary weight regulators place on acquisition submissions.
Dunne and Fenech: the Tribunal recalibrates FCA penalties, not principles
The Upper Tribunal upheld the FCA's bans on two individuals central to a £126m defined benefit pension transfer scandal, but cut their fines after finding only 18% of advice was unsuitable, not all of it. For senior leaders, the ruling clarifies how enforcement outcomes will be tested on evidence, and reinforces that dishonesty toward the regulator remains a career-ending line.
Relevant guides
How to Construct a Defensible ICAAP Narrative Aligned to Board Risk Appetite
This guide sets out how to build an ICAAP narrative that connects capital assessment to board-owned risk appetite in a way supervisors find credible. After reading, you will know how to structure the story, where the weak points usually sit, and what evidence to marshal before submission.
How to Design a Board-Approved Recovery Plan That Meets PRA Resolvability Expectations
This guide sets out how to build a recovery plan that credibly satisfies the PRA's resolvability expectations and earns genuine board ownership. After reading, you will know how to sequence the work, sharpen the judgement calls, and avoid the drafting habits that undermine credibility with supervisors.
How to Design a Board Effectiveness Review That Goes Beyond Box-Ticking
This guide sets out how to commission and run a board effectiveness review that produces genuine insight into how your board functions, not a comfortable report that gathers dust. Readers will finish with a clear method for scoping, evidencing, and acting on a review that shareholders, regulators, and directors themselves will take seriously.
Regulated Industry Governance Best Practice: A Practical Guide
This guide sets out what good governance actually looks like in regulated financial services, focusing on the judgement calls that separate credible boards from compliant-on-paper ones. Readers will finish with a clearer view of where their current governance falls short and what to change first.
How to Build a Credible Consumer Duty Board Report That Withstands FCA Scrutiny
This guide sets out how to produce an annual Consumer Duty board report that demonstrates genuine oversight, not compliance theatre. After reading, you will know how to structure evidence, handle uncomfortable findings, and give the board a document that stands up to supervisory challenge.
What Makes a Decision Defensible to Regulators: A Practical Guide
This guide sets out what regulators actually look for when they test whether a decision was sound, and how senior leaders can build that quality into decisions before they are made. After reading, you will be able to structure, document, and defend material decisions in a way that stands up to supervisory scrutiny months or years later.