Holding an FCA licence means living compliance every single day. For Banked, this involves running high-speed, account-to-account payments for enterprise customers at scale, while being able to prove at any moment that every control is in place and every risk is understood. In a world where money moves instantly, the real challenge is keeping compliance moving just as fast without slowing payments or adding friction for customers.
That challenge sits at the core of Banked’s operating model. The company delivers real-time, bank-authenticated payments for consumers, businesses, and banks across the UK, Europe, Australia, and the United States. Payments move directly between accounts with no interchange fees or settlement delays, giving merchants faster checkouts and lower costs. But while the account-to-account model reduces certain risks by design, the speed, scale, and cross-border reach create new ones that demand constant vigilance.
Flagright’s exceptional customer support has played a pivotal role in facilitating the expansion of our AML operations. They efficiently address all our requests.
Before Flagright, compliance reviews relied on SQL queries, which offered a degree of versatility, but the team wanted to future-proof operations for the pace of real-time payments. When Flagright came onboard, Banked’s immediate goal in implementing detection logic was to establish a broad baseline that could cover all essential compliance scenarios.
From the outset, new scenarios were benchmarked against the FCA’s published examples of good and poor practice, ensuring every rule demonstrated clear dynamic detection capability. The shift in approach was evident right away: SQL queries were no longer needed, and the compliance team gained the speed and autonomy to refine detection logic on the same day.
McCloud recalls,“If I built rules and the output was not quite what I expected, I had simulations and shadow testing to rely on without affecting production.”
Flagright’s impact metrics showing significant reductions in false positives and manual review workload.
Banked continued tailoring rules for its specific risk scenarios, in line with FCA guidance that makes clear a static set of rules is not sufficient; they must reflect the firm’s actual risk profile and evolve as risks change. For Banked, this meant refining the initial setup so that detection logic could adjust in real time based on merchant type, geography, and transaction patterns. The system now applies rule thresholds aligned with each merchant’s risk level, making payments from high-risk merchants more likely to trigger alerts than identical transactions from lower-risk merchants. This approach directly aligns with the FCA’s expectation that monitoring logic should be proportionate to a firm’s actual risk exposure.
McCloud says this keeps the system sharp: “The FCA handbook is actually really useful for that. I can look at those examples, check where we sit, and use the tool to know whether the change would actually improve detection.”
Adding Depth with Risk Scoring
For Banked, rules address specific typologies, but risk scoring makes it possible to combine multiple signals into a single picture of exposure. In their business model, factors such as merchant category, payment size, customer history, and geography all contribute to the calculation. Flagright’s IP enrichement capability adds another layer by identifying transactions initiated from high-risk countries, even if every other detail looks routine. This layered approach ensures that context is always part of the monitoring process, not just isolated red flags.
The scoring framework was introduced gradually. Alongside rules, Banked began with a broad model to understand how different inputs interacted before refining the weightings so that the riskiest transactions naturally moved to the top of the review queue. Over time, Banked benefited from enhanced risk algorithms and added functionalities, such as automated overrides of risk levels when certain criteria are met, or conversely, the ability to exclude risk factors when conditions are not satisfied, helping keep risk levels accurate and proportionate.
Today, rules and scoring work together in real time, enabling Banked to address both straightforward typologies and complex, multi-signal risks. The ability to test risk scoring configurations against self-built or automated samples of users and transactions has proved to be a valuable safety net, allowing the team to experiment without risk.
McCloud says the balance between adaptability and stability means the compliance framework can adjust quickly while remaining consistent in performance.
Always Ready for the Knock
With these capabilities in place, Banked has built a monitoring framework that is proportionate, effective, and ready for scrutiny. The FCA is known for showing up without notice, whether as part of a routine review or in response to a complaint, and can request detailed evidence of controls at any time.
Client testimonial from Banked’s Group Head of AFC & MLRO on Flagright’s impact on compliance agility and operational efficiency.
Banked operates as if that call could come tomorrow. Every process is documented, every rule change is logged, and every detection scenario can be reproduced on demand. With Flagright, audit trails, live monitoring, and investigation tools are all in one place, making it easy to demonstrate exactly how risks are identified and managed. The result is a compliance environment that remains FCA-ready every day without slowing payments or creating friction for customers.
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