Case Study — Asset Management / Risk & Compliance Advisory
An asset manager that had outsourced a third of its middle office eighteen months earlier needed its internal control ownership reviewed, after several control owners left without formal reassignment.
The Transformation Framework™
A third of middle-office functions had been outsourced eighteen months earlier, and several internal control owners had since left without their responsibilities being formally reassigned.
The outsourcing contract specified which functions the provider performed, but not which internal role remained accountable for oversight — an ambiguity that surfaced only when internal audit flagged three controls with no identifiable current owner.
We recommended a full control-ownership mapping exercise against the outsourcing contract, assigning a named internal owner for oversight of every outsourced function regardless of who performed the work.
All outsourced functions were mapped against internal oversight owners within ten weeks, with quarterly attestation now required from each named owner confirming the provider's performance against agreed service levels.
The three previously unowned controls now have named owners and documented oversight evidence. The firm's subsequent audit cycle found zero unowned controls across the full outsourced scope, against three in the prior cycle.
Measured Outcomes
Reflection
"Outsourcing an activity was never the same thing as outsourcing accountability for it, but the contract read as if it was."
Nina Kapoor — Head of Risk & Compliance AdvisoryEngagement team
Head of Risk & Compliance Advisory
Principal, Asset Management
Senior Consultant