Case Study: Enterprise Risk Management (ERM) Framework for a Pre-IPO Payments Fintech
Client Overview
The client was a fast-growing Payments Fintech preparing for its Initial Public Offering (IPO). The company had rapidly expanded its global footprint, offering merchant services, digital wallets, and embedded payment solutions to enterprises and SMBs. While its technology and market presence were strong, its risk governance and control framework needed to meet the expectations of regulators, auditors, and potential investors.
Business Challenge
As the company approached the IPO stage, it faced significant challenges:
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Lack of a formalized Enterprise Risk Management (ERM) structure.
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Inconsistent risk policies and procedures across business units.
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Limited visibility into key operational, technology, and compliance risks.
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No standardized Risk Control Self-Assessment (RCSA) or central repository for controls and issues.
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Board and management reporting on risk lacked standardization and meaningful metrics.
The leadership sought to institutionalize a robust ERM framework to strengthen internal governance, satisfy regulatory requirements, and instill confidence in potential investors.
Our Approach
We partnered closely with the client’s Risk and Compliance leadership team to design and operationalize a comprehensive ERM program, aligned with COSO and ISO 31000 frameworks.
1. ERM Framework Design
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Defined the risk governance model, including Board, Management, and Risk Committee roles.
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Developed a three-lines-of-defense model ensuring clear accountability for risk ownership.
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Created a Risk Appetite Statement tailored to the firm’s strategic and operational goals.
2. Policies and Procedures
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Conducted a policy and procedure inventory to identify redundancies and gaps.
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Updated and standardized all risk-related policies covering:
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Information Security
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Third-Party Risk Management
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Fraud and Operational Risk
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Business Continuity and Incident Response
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3. Risk and Control Framework
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Built a risk taxonomy across strategic, operational, compliance, financial, and technology domains.
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Mapped risks to controls, ensuring alignment with regulatory expectations and best practices.
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Established a centralized Controls Library to support ongoing assessments and audits.
4. Risk Control Self-Assessment (RCSA)
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Designed and deployed an RCSA methodology to identify, assess, and monitor key risks.
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Facilitated risk workshops with business and technology leaders to establish baseline ratings.
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Developed heat maps and dashboards for management insight.
5. Issue and Incident Management
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Implemented a structured process for issue identification, remediation tracking, and closure.
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Integrated incident reporting with management escalation protocols.
6. Management and Board Reporting
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Designed comprehensive Risk Reports and KRIs/KPIs for leadership and Board-level visibility.
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Established a monthly Risk Committee deck with trending metrics, control health, and open issues.
Outcome and Impact
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A fully functional ERM Framework that aligned with IPO readiness and audit standards.
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Enhanced risk visibility and accountability across all lines of defense.
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Improved board oversight and decision-making with timely and data-driven risk insights.
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Created a foundation for sustainable risk culture and continuous compliance improvement.
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Positioned the client strongly for IPO due diligence and ongoing regulatory examinations.
Key Highlights
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Delivered the complete ERM framework within 16 weeks.
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Conducted enterprise-wide training for risk owners and control leads.
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Integrated the ERM model with the client’s GRC technology roadmap for automation.