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Global Payments Firm Achieves EU DORA and FCA Operational Resilience Compliance Through Supplier Exit Planning

16 weeks from instruction.

The challenge

From Relationship to Readiness: Building a Stressed Exit Plan for a UK Private Bank's Critical Payment Technology Supplier

A global payment services provider offering a comprehensive range of services designed to support businesses in managing and optimising their payment operations identified a compliance gap in its obligations under both FCA Operational Resilience (SYSC 15A) and the EU's Digital Operational Resilience Act (DORA). The firm's most critical ICT third-party service providers, including an intra-group arrangement, had not been subject to structured exit planning in line with regulatory requirements. The organisation recognised that continuity of critical functions and important business services in the event of a supplier failure or exit scenario could not be credibly demonstrated without documented, tested supplier exit plans. The firm required a full-service support model: from initial alignment and risk assessment through to workshop facilitation, plan documentation, feasibility testing, and formal approval gate submission

 

What FourthLine delivered

  • Structured review of the Bottomline Technologies material outsourcing arrangement: services provided, IBS dependencies, contractual terms, and fourth-party concentration risk. 

  • Four material risk scenarios identified and risk-rated, covering technology failure, cyber attack, data breach, and supplier financial distress. Scenarios calibrated to IBS impact and likelihood. 

  • Amber and red monitoring thresholds designed and assigned across financial stability, operational performance, cyber and information security, and regulatory compliance indicators. 
  • Assessment of available contractual levers including step-in rights, documentation escrows, IP rights, key personnel clauses, termination-for-cause provisions, and transitional support obligations. 

  • Role-assigned response structure mapped to exit scenarios. Crisis governance structure, escalation protocols, and senior management accountability (SMF24) defined for each scenario. 

  • Remediation actions across operational readiness, supplier monitoring, and contract management workstreams. Actions assigned to named owners with target completion dates and priority classification 

The engagement produced the foundational exit planning infrastructure the bank had not previously had: a structured, evidence-generating document covering the scenarios that could force a stressed exit from its most critical payment technology supplier, the contractual tools available to manage that transition, and the governance and operational readiness framework required to execute it under pressure. 
 
The most significant operational outcome was the establishment of a calibrated monitoring framework: amber and red thresholds designed to provide the bank's executive and board with structured early warning of deterioration in the Bottomline Technologies relationship, ensuring that the decision to invoke the exit plan could be taken with appropriate lead time rather than in reaction to a crisis. Combined with the contractual gap analysis, this gave the bank's SMF24 holder a defensible position on the firm's TPRM readiness for the first time.
 
The engagement also established the evidence base needed to support the bank's next annual contract negotiation with Bottomline Technologies, providing a structured articulation of the contractual protections required and the gaps that needed to be closed before the renewed agreement could be considered operationally adequate from a resilience perspective.
The firm entered its PRA supervisory meeting with a complete, evidenced operational resilience programme. The board evidence pack provided the regulator with the documentary record it requested on day one of the review. 
Hampden & Co Bank
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