CM April 2025
THE CICM MAGAZINE FOR CONSUMER AND COMMERCIAL CREDIT PROFESSIONALS
THE CICM MAGAZINE FOR CONSUMER AND COMMERCIAL CREDIT PROFESSIONALS
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CREDIT MANAGEMENT
CM
APRIL ISSUE 2025
THE CICM MAGAZINE FOR CONSUMER AND
COMMERCIAL CREDIT PROFESSIONALS
Platform
Delays
Why do big banks
struggle with tech?
Guidance on the new
Failure to Prevent Fraud
offence. Page 16
Are we about to face a
new tsunami of debt?
Page 38
SEAN FEAST FCICM
MANAGING EDITOR
Editor’s column
IS THERE
SOMETHING YOU’RE
NOT TELLING ME?
IN our January/February magazine we
published a challenging and thoughtprovoking
piece about Short Firm Fraud
and asked whether Credit Reference
Agencies (CRAs) were doing enough
to address the issue. The author,
James Campbell, highlighted four
cases which in total had cost suppliers in excess of
£200,000.
In every case, he showed how there had been an
over-reliance on CRA recommendations and
concluded that CRAs are no nearer to being
able to spot a bogus account today than they
were five or so years ago, despite significant
advances in technology. He also suggested that
CRAs could do much more to warn their
subscribers of the potential shortcomings in their
recommendations, or in the dangers of relying on
their recommendations alone.
James supported his arguments with various
examples to prove his point and posed a series of
questions to the industry. In summary, he challenged
CRAs to demonstrate that they could spot bogus
accounts by way of a test, with the results published
in this magazine.
Having thrown out the challenge, I expected some
sort of response, even if only a gentle word in my
ear to back off or provide an off the record briefing.
But so far there has been radio silence. James contacted
the Business Information Providers Association
(BIPA) which includes Experian, Equifax, Creditsafe,
Dun & Bradstreet, Company Watch and Vistra for
an industry response, but also – so far – nothing.
The outgoing BIPA Chair, Patrick Walsh, has
forwarded James’ request to each of the members
for their ‘review and consideration’ so let’s see
what happens. I have every faith, not least because
BIPA’s purpose is to ‘facilitate communication
between the commercial CRAs, government and the
business community (editor’s italics) to create greater
awareness of the data held, how that data is used, and
how it benefits business decisions and responsible
lending’.
So here is an opportunity for it to ‘communicate’
the benefits of the data it holds and the reports its
members provide. Let us all hope that we don’t find
ourselves a month down the line with ‘but answer
came there none’ (with apologies to Lewis Carroll,
the Walrus and the carpenter!)
Pretty much every credit manager I know sees CRAs
as a critical part of the credit decisioning process, a
point that James goes on to stress. Pretty much every
item of news I have ever seen or articles I have read
from a CRA talks about the importance of their data
in promoting business growth, and I believe them.
So given that everyone is on the same side, let us hope
that we get engagement from BIPA and its members.
If we don’t, some might take it as the equivalent of a
‘no comment’. And when anyone says ‘no comment’,
it just means there might be things they don’t want
you to know.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 3
contents
APRIL 2025 issue
13 – PLATFORM DELAYS
How can the Finance industry up its game to
build a future in the technological world?
16 – TAKEN IN EVIDENCE
Guidance on the new Failure to Prevent
Fraud offence.
20 – GREEN FLASH
AI is causing havoc in relation to the
monitoring of greenwashing in advertising.
24 – CLOCKED OFF
Are we in danger of losing our way at work?
26 – ARTIFICIAL REALITY
Building and Integrating AI Models in the
Financial Services Sector.
32 – COUNTRY FOCUS
Turkey is at a crossroads in more ways
that none.
38 – FLOOD WARNING
Is there a debt tsunami coming?
42 – EDUCATION OR EXPERIENCE?
Here are the three factors that really matter.
44 – AGE OF PROHIBITION
Selling union lists and the practicalities of
re-engaging wayward staff.
59 – CONSTRUCTIVE PROGRESS
Better outcomes for Government and
regulators.
12
INSOLVENCY
Why should directors
be concerned?
16
TAKEN IN
EVIDENCE
Guidance on the new
Failure to Prevent
Fraud offence.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 4
Tu
32
COUNTRY FOCUS
CICM GOVERNANCE
13
PLATFORM
DELAYS
20
GREEN FLASH
President: Stephen Baister FCICM
Chief Executive: Sue Chapple FCICM
Executive Board: Chair Neil Jinks FCICM
Vice Chair: Allan Poole FCICM
Treasurer: Glen Bullivant FCICM
Larry Coltman FCICM
Peter Gent FCICM(Grad)
Paula Swain FCICM
Advisory Council: Laurie Beagle FCICM
Laura Brown MCICM(Grad) / Arvind Kumar MCICM(Grad)
Natalie Bunyer FCICM / Glen Bullivant FCICM
Alan Church FCICM(Grad) / Larry Coltman FCICM
Peter Gent FCICM(Grad) / Neil Jinks FCICM
Martin Kirby FCICM / Charles Mayhew FCICM
Joshua Mayhew MCICM / Hans Meijer FCICM
Debbie Nolan FCICM(Grad) / Amanda Phelan FCICM(Grad)
Allan Poole FCICM / Emma Reilly FCICM
Philip Roberts FCICM / Paula Swain FCICM
Jonathan Swan FCICM / Mark Taylor MCICM
Atul Vadher FCICM(Grad) / Dee Weston FCICM
View our digital version online at www.cicm.com.
Log on to the Members’ area, and click on the
tab labelled ‘Credit Management magazine.’
Credit Management is distributed to the entire
UK and international CICM membership, as well
as additional subscribers
rkey
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 5
Publisher
Chartered Institute of Credit Management
1 Accent Park, Bakewell Road, Orton Southgate,
Peterborough PE2 6XS
Telephone: 01780 722900
Email: editorial@cicm.com
Website: www.cicm.com
CMM: www.creditmanagement.org.uk
Managing Editor: Sean Feast FCICM
Deputy Editor: Iona Yadallee
Art Editor: Andrew Morris
Telephone: 01780 722910
Email: andrew.morris@cicm.com
Editorial Team
Rob Howard, Milica Cosic and
Melanie York
Advertising
Paul Heitzman
Telephone: 01727 739 196
Email: paul@centuryone.uk
Printers
Stephens & George Print Group
2025 subscriptions
UK: £138 per annum
International: £171 per annum
Single copies: £15.00
ISSN 0265-2099
Reproduction in whole or part is forbidden without specific permission.
Opinions expressed in this magazine do not, unless stated, reflect those
of the Chartered Institute of Credit Management. The Editor reserves
the right to abbreviate letters if necessary. The Institute is registered as a
charity. The mark ‘Credit Management’ is a registered trade mark of the
Chartered Institute of Credit Management.
Any articles published relating to English law will differ from laws in Scotland and Wales.
THE NEWS
CMNEWS
A round-up of news stories from the
world of consumer and commercial credit.
WRITTEN BY: SEAN FEAST FCICM
Small businesses show
big appetite for personal
guarantee backed finance
SMALL businesses appear
to be increasing their
financial resilience in the
face of increasing costs,
according to new research.
A survey by Purbeck
Insurance Services suggests
that in the final quarter of 2024, there was a
25% increase in small businesses applying for
personal guarantee (PG) backed business
loans compared to the same quarter of 2023.
Indeed, for the whole of 2024 there was a
45% increase in small businesses taking on
PG backed finance. The insurer believes
this is proof of how personal guarantees
have become a standard requirement in
small business lending.
Underlining the increased level of
entrepreneurship in the UK, 50% more
start-ups (firms that have been established
for under two years) applied for funding
in Q4 2024 and the average loan to these
young businesses jumped from £100,399 in
Q4 2023 to £121,668 in Q4 2024 – this is a
21.28 % year-on-year increase.
In contrast, the average loan taken by a
firm over two years old rose marginally by
6% from £238,645 in Q4 2023 to £254,203
in Q4 2024. Across the board, the average
loan value was £174,627 in Q4 2024 up from
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 6
CREDIT MANAGEMENT
“The fact that
small businesses
are increasingly
using insurance
to mitigate some
of the risks
associated
with personal
guarantee
backed loans
shows they are
taking positive
steps to improve
their financial
resilience”
£159,664 in Q4 2023. Principal reasons for
requiring a loan were to provide working
capital (33% of applications) and for
investment in growth initiatives or business
acquisitions (22%).
Todd Davison, Managing Director of
Purbeck Personal Guarantee Insurance
believes there is a good deal of realism
and pragmatism amongst small businesses
in the face of increasing business costs
following the Budget in October 2024:
“Small firms know they need to adjust
to increased cost pressures and personal
guarantee backed finance can help them
through – whether that's via their bank, an
alternative businesses lender or through
initiatives such as the Growth Guarantee
Scheme.
“The fact that small businesses are
increasingly using insurance to mitigate
some of the risks associated with personal
guarantee backed loans shows they are
taking positive steps to improve their
financial resilience,” he adds.
“It remains vital, however, that firms
familiarise themselves with the risks of
personal guarantees, particularly those
that form part of the Growth Guarantee
Scheme. This scheme does not protect a
business owner from a personal guarantee,
it protects the lender. There should be no
misunderstandings over the guarantor’s
liability should be the business ultimately
fail.”
Outlook for SMEs hit
hard since Labour win
TAXES remain the biggest obstacle to
SME growth, and more SMEs are now
struggling to source finance since Labour
came to power than under the previous
Government.
New data from iwoca’s Q4 SME Expert
Index suggests that almost three-quarters
(70%) of commercial finance brokers
believe that conditions for SMEs have
worsened since the Labour Government
took office, and small business owners are
increasingly anxious about the future.
As such, lower taxes are finance brokers’
top choice to drive SME growth in 2025
(38%) — twice as many as the next most
popular measure of business rates reform
(19%).
Increased business running costs for
SMEs remain the biggest concern for
more than half of finance brokers (53%),
up 11-points on the previous quarter.
Concerns over inflation also remain
high — with two-thirds (67%) of finance
brokers believing inflation will be above
Charity calls for action
on issue of ‘coerced debt’
A small but possibly growing number
of UK adults have experienced coerced
debt, a form of economic abuse where the
perpetrator coerces a victim into debt,
making them take out credit against their
wishes.
New research by StepChange Debt
Charity reveals around 3% of UK adults,
equivalent to 1.6 million people, have
suffered in this way and that around one
in eight (12%) of its debt advice clients are
impacted by it.
StepChange says that patchy and
inconsistent support, legislative barriers,
and inflexibilities in credit reporting
prevent victim-survivors from rebuilding
their lives and regaining economic
stability. The charity is calling for the
Government to establish a taskforce
to ensure victim-survivors can achieve
economic justice through economic
safety and stability without having to pay
the price for an abuser’s behaviour.
Currently, victim-survivors face years
repaying coerced debt, extending the
impact of abuse and tying victims to
a perpetrator. Often victim-survivors
struggle to make ends meet due to
debt repayments, experience financial
exclusion due to negative impacts on
their credit report and, in some cases, are
the Bank of England’s 2% target by the end
of the year, with 32% predicting it will top
2.6%.
However, despite continued concerns
about barriers to growth, economic
optimism bounced back in the last quarter
of 2024, with almost half of SME finance
brokers (46%) reporting feeling optimistic
about SMEs’ future in 2025, compared to
36% in the previous quarter. Following a
sharp decline after the Budget, this signals
a glimmer of hope for the year ahead, as
pessimism has gone down.
Worries persist about a recession, as
more than half (51%) are concerned about
the possibility – a slight increase on last
quarter.
Colin Goldstein, Chief Commercial
Officer, UK at iwoca, says SMEs are
facing rising costs and tougher borrowing
conditions: “With high street banks
pulling back, businesses are turning to
alternative lenders to access the funding
they need.”
barred from working in certain jobs.
National YouGov polling commissioned
by StepChange for the report reveals low
public awareness of coerced debt and
economic abuse: almost seven in ten
(68%) people have never heard of the term
‘coerced debt’ and for those who have
fallen victim, the majority (58%) had not
sought advice or support.
Vikki Brownridge, CEO at StepChange
Debt Charity, believes that those who
have experienced coerced debt should not
pay the price for their abuser’s behaviour:
“Restoring a victim-survivor’s finances
can be a long and complex process,
particularly in the case of joint debts
and joint mortgages. The challenge of
dealing with debts that have been coerced
is compounded by the emotional and
mental health impacts of abuse.
“Our research highlights the urgent
need for Government leadership and a
collaborative approach from regulators,
financial services and advice agencies in
supporting victim-survivors to regain
financial control and ensure they do not
spend years paying back coerced debts. A
more consistent approach to debt-write
off and credit file restoration are two
key recommendations that would help to
achieve this.”
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 7
continues on page 8 >
THE NEWS
Young Britons struggling
with debt and budgeting
YOUNG adults in
the UK are facing
significant financial
struggles, with
many battling debt
and seeking help
with budgeting.
Research carried out by Opinium for
Christians Against Poverty (CAP) found
that 35% of young adults are struggling with
deficit budgets – spending more than they
earn – a far higher number than the 9% of
over-55s in the same situation. Some 13% of
18-24s say they have had to borrow just to
afford food compared to 8% of 35-54 yearolds,
3% of 55+ and 2% of 65+.
These financial pressures and the easy
availability of credit cards and Buy Now
Pay Later schemes have led many young
people into debt. Three in ten (30%) 18-34
year-olds report struggling to repay debt,
compared to 23% of those aged 35-54 and
just 7% of over-55s.
With borrowing increasingly normalised,
younger generations are more reliant on
credit for education, housing, and day-today
expenses than previous generations.
The rise of high-interest credit products
and the growing number of households
borrowing more and saving less are
ringing alarm bells about the long-term
financial vulnerability of many young
people. Over half (52%) of young adults -
equating to more than 7.8 million people –
say they need support with budgeting. CAP
is warning that without better financial
education and support, young Britons risk
becoming trapped in a cycle of debt.
Juliette Flach, Policy & Public Affairs
Manager, CAP, warns that young people
face a higher risk of being pulled into
financial difficulty and spiralling debt:
“Not only are they in lower-paid jobs at
the start of their careers, but they have
not yet had time to build up financial
savings and are less likely to receive family
inheritances. Poverty and debt have an
immediate impact, but they can also have
a long-term impact as poverty can persist
over someone’s lifetime.”
While measures to help safeguard
pensioners, such as the ‘triple lock’ have
gone some distance in reducing poverty for
people who are pension age, there isn’t an
equivalent for young people.
CAP is calling on the Government to
establish a protected minimum amount
of social security, known as an Essentials
Guarantee so that the basic rate of social
security always covers life’s essentials and
ensures support is never pulled below that
level. In addition, CAP wants employers to
ensure wages are sufficient to prevent any
worker from facing a deficit budget.
CSA appoints Desmond Hudson as new Chair
THE Credit Service Association (CSA), the
UK trade body for the debt collection and
purchase industry, has appointed Desmond
Hudson to succeed Tom Chandos as new
independent chair.
Desmond Hudson’s career spans several
high-profile positions, including Chief
Executive of the Law Society of England
& Wales and the Institute of Chartered
Accountants of Scotland. In both roles
he advanced regulatory frameworks and
enhanced professional standards.
Chris Leslie, CSA CEO, says that
Desmond’s appointment comes at an
important time for the Association:
“With the Government and regulators
now realising that economic growth must
be at the heart of new policies, we have
an opportunity to emphasise how credit
availability – for which a well-functioning
collections process is integral – must be
front and centre of their thinking. The CSA
represents our sector but also supports
member firms with services, networking
and new policy thinking. Des will be a great
asset in this endeavour.”
Desmond’s appointment was confirmed
at the CSA’s Annual General Meeting
which also saw something of a changing
of the guard of the CSA Board: Kathryn
Morgan, Managing Director of Lowell,
succeeded Nick Cherry of Phillips and
Cohen Associates (PCA) as Deputy Chair
and six other Board members were elected/
re-elected.
The six comprised: Frank Horvath,
Managing Director at Link Financial
Outsourcing; Claire Moore, Chief Risk
Officer at Azzurro Associates; Susan
Bain from Zinc Group; Sam Barnard,
Commercial Director at Lantern Group;
Stuart Webb, UK Site Director at PCA;
and the Chief Operating Officer at Cabot
Financial, Jaime Nuwar–Graham.
Commenting on the appointments, Chris
added: “Our CSA Board is drawn from
across the collections and debt purchase
sector, elected democratically at our AGM
from among our member firms, and they
will ensure the voice of the sector is heard
clearly and our work truly represents
the real-world issues in collections and
recoveries.
Chris also thanked the outgoing
executives for their contributions: “Tom
Chandos brought with him a wealth
of experience, impartiality, and proven
business acumen. His support for the
Association and the wider board over his
long tenure will be sorely missed.”
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 8
Gold Award winners
CICM Corporate Partner Top Service has
been awarded the Gold Award under the
new Fair Payment Code, introduced by the
Small Business Commissioner in January.
The award is said to recognise the company’s
commitment to ethical and fair payment
practices in the UK construction industry.
The Fair Payment Code replaces the
previous Prompt Payment Code, aiming to
tackle the widespread issue of late payments
that continue to challenge suppliers and
subcontractors. While the initiative is a
positive step forward, Top Service believes
that further measures, including statutory
backing, could significantly strengthen its
impact and bring about real, lasting change
for businesses operating in the construction
sector.
Emma Reilly FCICM, CEO of Top
Service says the true effectiveness of the
Code will depend on widespread adoption
and integration into risk assessments by
businesses and government departments
when evaluating tenders: “Making fair
payment a legal obligation could truly
transform the industry and protect the
smaller suppliers and subcontractors who
are often most affected by late payments,”
she says.
Sue Chapple FCICM, CEO of the CICM
is delighted to see one of the Institute’s
Corporate Partners in the vanguard
of best practice: “We are absolutely in
support of the FPC and the Small Business
Commissioner in her endeavours to further
improve payment practice,” she says, “and
agree that lasting change will require a firm
commitment from all.
“Enforcement will be the key to its
success, as will the ongoing support of the
Government and business organisations
who must continue to match words with
actions and not allow their support to waver
at the first sign of difficulty.”
The FPC is designed to reward businesses
for their payment performance with an
award of Gold, Silver or Bronze. The Gold
Award is for those firms paying at least
95 percent of all invoices within 30 days;
the Silver Award for those paying at least
95 percent of all invoices within 60 days,
including at least 95 percent of invoices
to small businesses within 30 days; and
the Bronze Award will be given to those
paying at least 95 percent of all invoices
within 60 days.
THE NEWS
Boost for women
WOMEN who start their own businesses
report a significant boost in confidence,
resilience, and self-belief despite many
feeling the stress of ‘entrepreneurial load',
according to new research from Small
Business Britain and Starling Bank. The
research, gathered from 1,000 female
entrepreneurs for International Women’s
Day last month, found four in five (80%)
feel more confident in their abilities
after launching their business, with 87%
feeling happier. However, respondents
acknowledged the demands on their time,
with 60% struggling to switch off from work
and 39% reporting stress and exhaustion.
Everyday rebrand
EVERYDAY Loans has rebranded as Evlo
and appointed consumer credit expert
Deborah Green as Chief Operating Officer
to help drive the company’s next stage of
growth. Evlo says the rebrand embodies
the company’s focus on financial inclusion,
transparency, simplicity and customercentricity.
The company also says it signals
a renewed emphasis on helping customers
improve their credit scores and gain access to
mainstream financial products, as opposed
to just offering short-term lending solutions.
Credit Information and
Debt Recovery Services for
the Construction Industry!
Up to the minute trading experiences & payment data
specifically for the construction industry
Company & Director monitoring
Debt Recovery solutions to suit you, your business
and customer relationships
A team of credit experts that really understand credit
management in the construction industry
Contact us to discuss how we can support you and
your business to minimise debt and maximise cash
Supporting the
construction
industry for over
30 years
01527 503990 membership@top-service.co.uk www.top-service.co.uk
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 9
continues on next page >
CICMQ NEWS
Royal Mail receives fourth Accreditation
ROYAL Mail’s Receivables Team has once
again demonstrated its commitment to excellence,
securing CICMQ Accreditation
for the fourth time since its initial recognition
in 2015. This achievement highlights
the team's industry-leading credit management
practices and operational expertise.
Maintaining this prestigious accreditation
reflects Royal Mail’s ability to uphold
best-in-class credit operations that enhance
financial stability and efficiency.
The latest assessment reaffirmed by Luke
Sculthorp FCICM, Head of Strategic Relationships,
who served as the Assessor for
this accreditation, ensuring rigorous evaluation
and validation of best practices. Areas
particularly noted include the team’s strong
credit policy and governance, effective risk
management, and collaboration across
sales, finance, and leadership, its proactive
approach to dispute resolution alongside
a commitment to continuous professional
development.
The accreditation is a testament to
the team’s essential role within Royal
Mail. Glenys Hayward, Head of Finance
Shared Services, praised the team’s impact:
“The Accounts Receivable team is absolutely
essential to our business. The
team is recognised across the stakeholder
ommunity as a critical function with a fundamental
impact on cashflow and working
capital. Stakeholders commended the
team’s transparency, professionalism, and
problem-solving capabilities, reinforcing
its reputation as a critical function within
the organisation. Colin Robinson and Sam
Nuttal MCICM, were also instrumental in
this success, contributing their expertise
and dedication to strengthening credit
operations and driving efficiency. Their efforts,
alongside the wider team, have been
pivotal in securing this accreditation.”
While this reaccreditation is a significant
achievement, the team remains committed
to continuous improvement. Future
priorities include process improvement,
enhancing collaboration with the
Sales team, increasing direct customer
engagement, and leveraging the benefits
of key system transformations currently
underway. With a forward-thinking
approach, Royal Mail’s Receivables Team
continues to set the benchmark for credit
management excellence.
The Credit Industry Credit Management
Quality team have also been busy assessing
other teams, and re-accreditations have
been achieved by Impellam Group, Tarmac
Trading, Wesco Anixter MEA in recent
weeks. Presentations are being arranged to
celebrate their success.
Vulnerable under pressure
as consumer optimism falls
ONE in five (20%) UK adults – the
equivalent of 11 million people – now
consider themselves financially vulnerable
and consumer optimism is dropping
rapidly, especially among middle income
families.
According to the Financial Conduct
Authority, financially vulnerable consumers
are susceptible to harm, due to
their personal circumstances, including
poor health, life changes like new caring
responsibilities, or difficulty handling financial
or emotional stress.
Data from TransUnion shows the impact
of money worries on mental wellbeing,
with nearly seven in 10 (68%) financially
vulnerable people feeling stressed when
dealing with their finances.
The cost of living remains high; more
than a quarter (26%) of UK adults are
relying on credit cards to meet shortfalls
in their monthly finances, while 16% dip
into their overdrafts. Meanwhile, 15% of
UK adults borrow money from friends
and family in order to be able to afford
their monthly expenses, whilst over one
in 10 (12%) turn to Buy Now, Pay Later
(BNPL) services. Overall, one in 10 (10%)
adults report that they wouldn’t be able
to maintain their current lifestyle without
credit or financing options. Indeed, this
reality was reflected in TransUnion’s Q4
2024 Consumer Pulse data that suggests
consumer optimism has dropped by a
significant 9% among middle income
families (those earning between £30,000
and £79,999), falling from 57% who
were optimistic about their household
finances over the next 12 months to 48%.
Lower income families (those earning
under £30,000 annually) remain the least
optimistic, with only 37% stating they are
optimistic about their household finances
over the next 12 months, highlighting
the continued strain on more financially
vulnerable households.
However, many more struggle to
consistently access credit, with 9%
indicating having been turned down
within the last 12 months. 35-44-year-olds
(18%) were the most likely age demographic
to have a credit application rejected. The
most common reason people said they
were turned down for when looking to
borrow money, is a low credit score (33%)
– a demonstration of the importance of
understanding and regularly monitoring
your credit report.
OBITUARIES
Mike Wykes FCICM
CREDIT Management is sad to report
the death of Mike Wykes FCICM, past
Chairman of the London Branch of the
CICM. Mike, who started his career in
credit as a despatch rider for Coopers
and Lybrand, rose to become an Associate
Director of Smith & Williamson prior to
launching his own consultancy. An obituary
to Mike will follow in a future issue. In the
meantime, the team would like to express
their condolences to Mike’s family.
Colin Hingston FCICM
CREDIT Management has also learned of the
sudden passing of Colin Hingston from a
suspected heart attack. Colin was a longtime
member and supporter of the Institute
and former European Credit Manager at
Instron, the international manufacturing
business. The team would like to express
their condolences to Mike’s daughter and
family. An obituary will similarly follow
in a future issue.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 10
INSOLVENCY
TRADING ON
WHILST INSOLVENT
Why should directors be concerned?
BY GIUSEPPE PARLA
DIRECTORS have a fiduciary duty to
promote the success of the business
for the benefit of its shareholders.
However, when a company begins
to head towards insolvency, the
directors’ primary duty should shift
to protecting the creditors’ position
from worsening further.
Where a director ought to have known that the company
was insolvent and should have therefore ceased trading at
an earlier point, a director can be personally liable for the
resultant loss to the company and its creditors.
As an example, if an insolvent company had an amount
owed to its creditors in the region of £2m but then trades
on for a further three months where the losses increase
further to £2.5m, then the directors can be personally liable
for £500,000. The reason for this, is that they should have
been taking steps to wind down the business and cease
trading at a much earlier time to avoid those increased
losses.
A liquidator or an administrator can bring a wrongful
trading claim against an offending director.
Whilst all directors are expected to have a certain level
of competence, and ignorance is no defence, those with
a higher level of qualification will be held to a higher
standard. So, a qualified accountant acting as a director
of a company, will be expected to have known about
the insolvency at an earlier stage and therefore, the
repercussions for them could be more severe.
Directors need to tread carefully when they begin to have
cashflow problems and they should make sure that if the
position is expected to worsen in the short term, then it
should really only continue trading in anticipation that
in the long term, the company will return to a solvent
position.
It would be wise for Directors to seek independent advice
from an Insolvency Practitioner at an early stage and
consider having Directors & Officers insurance in place.
What changed in 2022?
The Supreme Court’s judgement in BTI 2014 LLC v
Sequana caused a major shift in the way that the insolvency
profession considers potential action in respect of
wrongful trading claims.
Before 2022, it was always felt there was a clearcut moment
in time when insolvency commenced, and creditors’
interests prevailed. However, in Sequana the Court found
that there was no one point in time at which a real risk
of insolvency could be placed, but that instead there
was a sliding scale during which the risk of insolvency
becomes more acute. As a result, the obligations of the
directors ‘shifts’ as the likelihood of insolvency goes from
being ‘remote’ to one that is ‘inevitable’, ‘irreversible’, or
‘unavoidable’.
As a result of this interesting judgement, Insolvency
Practitioners look a little more closely into the events
leading up to an insolvency and whether the directors
ought to have taken appropriate steps to make sure that
the position did not deteriorate further.
What are the implications
When you start to have difficulties in recovering a debt,
find out why and make a log of the communications.
Consider also whether you want to continue providing
credit to the company. If you are a supplier, consider
insisting on cash on delivery for future supplies.
Events leading up to an insolvency are key and your
communication log could prove pivotal if desiring to bring
a claim against an individual or demonstrate at what point
a director should have known the company was heading
towards insolvency.
Author: Giuseppe Parla is a Business
Recovery Directorand Licensed Insolvency
Practitioner at Menzies LLP.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 12
TECHNOLOGY
PLATFORM
DELAYS
How can the Finance industry up its game to build
a future in the technological world?
BY : STEVE KIELY
TECHNOLOGY – love it or loathe
it, the website, app, and chatbot
are, today, simply indispensable
parts of the Finance industry, just
as they are for society as a whole.
Entire generations have grown
up living in the online age, and, with Artificial
Intelligence on everyone’s agenda, there seems to be
no sign of things slowing down.
The problem, of course, is that you need to get it right
– in the ‘good old days’ maybe a customer might not
even notice if, for example, their local bank branch was
closed for the weekend. Now, if your app is offline for
a matter of minutes, your customer is up in arms, and
your organisation is facing a significant reputational
risk and potential financial penalty.
Unplanned outages
There have been all too many failures in recent times.
The reality was driven home, last month, when the
Treasury Select Committee revealed that nine of the
top banks and building societies operating in the
UK accumulated at least 803 hours – the equivalent
of more than 33 days – of unplanned technology and
systems outages in just the last two years.
At least 158 banking IT failure incidents affected
millions of customers’ ability to access and use services
between January 2023 and February 2025.
This does not even include the most recent outages
affecting Barclays customers between 31 January and 2
February and various banks on 28 February, disruption
which left many people distressed on payday and
prompted angry complaints from MPs. The Committee
warns that it will be requesting further information
from the organisations involved in those instances.
‘Severe degradation’
Despite not including the information in their
aggregated figures, Barclays confirmed that 56% of
online payments during the incident failed due to
‘severe degradation’ of its mainframe processing
performance. It expects to pay between £5m and £7.5m
in compensation to customers for ‘inconvenience or
distress’.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 13
continues on next page >
TECHNOLOGY
In fact, the Committee estimates that Barclays might need
to pay out up to £12.5m – well ahead of the second highest
amount paid by a lender in the last two years: £350,000 by
the Bank of Ireland.
Common reasons given for the IT failures include problems
with third-party suppliers, disruption caused by a change
in systems, and internal software malfunctions.
Chair of the Treasury Select Committee, Dame Meg
Hillier MP, does not mince her words: “For families
and individuals living paycheque to paycheque, losing
access to banking services on payday can be a terrifying
experience. Even when rectified relatively quickly, it can
cause real panic, which is why we wanted to get a proper
understanding of why unplanned banking outages happen
and how banks and building societies respond. And we
know some can go on for several days.
“The reality is that this data shows even the most successful
banks and building societies hit technical glitches. What’s
critical is they react swiftly and ensure customers are kept
informed throughout.”
Flawed execution
Barclays are far from the only lender to face significant
difficulties. This time last year, Nuno Matos, then Chief
Executive of HSBC Global Wealth and Personal Banking,
said that the bank would ‘attack’ the worldwide retail
payments market with the launch of Zing.
Matos said at the time: “It’s a bold move for us. This is
HSBC playing outside of its traditional perimeter of
customers, and really attacking, if you want, of taking
advantage of a contingent, which is big, is growing, looks
like us, and it’s here for us.” Exactly 12 months later,
HSBC admitted defeat in what had become an expensive
failure to challenge the established fintech payments
giants.
Joanne Kumire, lead banking and payments analyst at
GlobalData, said: “The app’s concept may have been sound,
but its execution was flawed from the start. Existing
customers were forced to undergo re-KYC, an unnecessary
hurdle. The product itself was incomplete, failing to offer
meaningful differentiation from Wise or Revolut.
“Worst of all, HSBC spent over three years developing
Zing before engaging with real users, sinking more than
$150m before generating any revenue. In contrast, Wise
and Revolut had already captured the market by rapidly
iterating their platforms, expanding globally, and building
deep customer loyalty.”
Need for speed
Kumire hits on a key consideration when she finds that
the underlying problem was not HSBC’s lack of talent
or resources, rather it was the cultural and structural
challenges that plague many large banks. Innovation at
scale requires speed, adaptability, and a willingness to
experiment, traits that ‘traditional’ financial institutions
often struggle to embody.
SORRY, PAGE NOT FOUND
“FOR FAMILIES
AND INDIVIDUALS
LIVING PAYCHEQUE
TO PAYCHEQUE,
LOSING ACCESS TO
BANKING SERVICES
ON PAYDAY CAN
BE A TERRIFYING
EXPERIENCE.’’
She adds: “There are valuable lessons to be learned from
Zing’s failure that banks must internalise to succeed in
today’s hyper-competitive financial landscape. Banks need
to prioritise moving quickly and gathering user feedback
early in the process to guide development.
“Additionally, excessive spending should be avoided until
there is clear evidence of product-market fit, and in many
cases, partnering with experienced providers may be far
more effective than attempting to build everything inhouse.”
Unravelling growth
One difficulty, of course, is that lenders are being required
to make such major investments in new products and
technology just at a time when their own financial base is
starting to look a little shaky.
The UK’s Financial sector has contracted significantly
since 2020, with nearly 10,000 firms disappearing in just
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 14
CREDIT MANAGEMENT
four years, according to The Payments Group. The decline
signals a deeper structural shift within the industry,
extending beyond the economic fallout of Brexit and the
pandemic.
Its analysis, based on UK Office for National Statistics data
spanning 2010 to 2024, paints a stark picture: after years of
growth, the sector has entered a period of consolidation,
technological disruption, and business failures. Banking,
financial management, and auxiliary financial services are
among the hardest-hit segments.
“The simple truth is that UK finance is shrinking,” says
Chief Executive, Jens Bader. “We are seeing a shift in
the industry’s foundations – one that could have lasting
consequences for the broader economy.”
He suggests that a mix of factors is reshaping the landscape:
• The rise of non-UK financial technology firms, including
American giants such as Apple and Google, which are
tightening their grip on the UK payments ecosystem.
•Regulatory and compliance burdens, particularly in
areas like anti-money laundering and financial-crime
prevention, which have increased operational costs for
smaller firms.
• Market shifts away from traditional financial services,
with mortgage finance emerging as one of the few growth
areas, reflecting the impact of rising interest rates and
sustained housing demand.
Identity and security
But the fact remains: success in the Finance industry
will increasingly rely on getting technology right, and
this technology can help give better, and more reliable,
customer service.
Advisers Cognizant believe that lenders are well placed
for a significant shift in identity management and security
approaches. Biometric authentication will evolve beyond
fingerprints and facial recognition to include behavioural
biometrics – and become the industry standard.
Blockchain-based decentralised identity solutions will
give customers greater control over personal data and
AI-powered fraud detection will revolutionise security.
Danske Bank’s much-heralded use of Machine Learning
to reduce false positives in fraud detection by 50% is, it
believes, just the beginning.
Rise of the super-app
And lenders do not have to do it all alone. Rather than
providing isolated services, many analysts believe that
the trend will shift toward comprehensive financial
ecosystems. ‘Super apps’, like China’s WeChat, which
integrates banking, shopping, and messaging, could inspire
similar platforms in the West.
André Burger, Senior Partner at Synpulse, insists that
banks can partner with fintech companies to develop these
versatile platforms. This would enable customers to use one
centralised app for all financial, and often non-financial,
needs – from account management to investments and
loan services.
In this ‘platform banking’, banks would act as an interface,
integrating various third-party providers to deliver a range
of services, allowing customers to manage finances and
access services such as insurance, real estate, bookings, or
even healthcare within one application.
Imperatives for success
So, despite all the concerns and challenges of the present,
there are still real opportunities for organisations and
professionals who are bold enough to pick up the gauntlet.
And, interestingly, many of the keys for success are the
very same that the industry has relied on for so many
major projects in the past.
Looking at ways to adapt to these challenges, Akhil Babbar,
a knowledge expert at management consultant McKinsey
& Company, points to some very familiar factors:
• Reduce complexity and avoid surprises by budgeting the
necessary time and resources up front.
• Estimate your technical debt – how far you need to travel
- and ensure that the initial budget includes the cost to
remove it; otherwise, the debt will lead to delays and cost
increases.
• Over-invest in cultural shift, even if it might not be
directly related to technology.
• Attract the right talent and do not try to outsource the
transformation.
• Break down organisational silos and design an
organisation-wide transformation road-map - not just by
business area.
Above all: measure the change, with agile practices
and processes in place, such as quarterly business
reviews, to allow for effective prioritisation and value
tracking. Traditional oversight should be replaced by
cross-functional collaboration, cross-silo performance
management, and a new concept of joint accountability
across the entire business. Along the way, successful
projects can be highlighted to inspire the team and build
momentum.
Conclusion
A large-scale digital transformation is not easy, and it is
not surprising that most banks struggle to achieve their
business objectives on time and within budget.
But take heart: the fundamentals for a successful project
are as true today as they have always been. Industry
professionals can take steps to avoid the most common
mistakes by defining clear goals and metrics that reflect
not only the business change, but also the cultural and
technical changes required.
By doing so, you can increase their chances for success and
reap the full rewards of your digital transformations.
Author: Stephen Kiely is a freelance buisiness writer.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 15
FRAUD
TAKEN IN
EVIDENCE
Guidance on the new Failure to Prevent Fraud offence.
BY SEBASTIAN SAYER AND
GLORIA PALAZZI
IN November last year, the Home Office
published its long-anticipated guidance
for corporates in relation to the new
Failure to Prevent Fraud (FTPF) offence
under the Economic Crime and Corporate
Transparency Act 2023 (ECCTA).
The FTPF offence creates criminal liability for certain
companies which fail to prevent fraud. If found guilty,
companies face unlimited fines.
The guidance, which runs to 44 pages, sets out examples
of good practice which may enable corporates to
demonstrate that they had in place ‘reasonable fraud
prevention procedures’ which provide a complete
defence against prosecution for the FTPF offence;
this will absolve them of criminal liability.
The guidance clarifies that the FTPF offence will
come into force on 1 September 2025. However,
there will be a transitional period designed to give
organisations adequate time to understand and
assimilate the guidance into their policies, procedures,
and practices.
The offence
Section 199 of ECCTA states that a criminal offence
is committed where a ‘person associated’ with a
‘relevant body’ commits an ‘offence’ intended to
benefit, whether directly or indirectly the relevant
body; or any person to whom, or to whose subsidiary
undertaking, the associate provides services on behalf
of the relevant body.
So, what does this mean?
Relevant body
Whilst the FTPF offence applies across all sectors
of the economy, it can only be committed by
‘large organisations’. This includes companies, and
partnerships, meeting at least two of the following
criteria – they have more than 250 employees, have a
turnover greater than £36m, or have more than £18m
in total assets.
These criteria apply to the whole organisation,
including subsidiaries, regardless of where the
organisation is headquartered or where its subsidiaries
are located.
Persons associated
Broadly speaking, this includes employees, agents, or
subsidiary undertakings of a company, or any person
who otherwise performs services for or on behalf of
a relevant body. Whether an individual is actually
performing services for an organisation may be a
question of fact.
Companies in an organisation’s supply chain, and
franchisees are not associated persons unless they are
providing services for or on behalf of the relevant
body.
Qualifying offences
The Act covers a wide range of fraudulent activities by
persons associated with an organisation. These include
offences such as fraud by false representation (under
the Fraud Act 2006), false accounting (under the Theft
Act 1968), fraudulent trading (under the Companies
Act 2006), and cheating the public revenue (under the
common law). Money laundering offences under the UK
Proceeds of Crime Act 2002 are not qualifying offences.
The Act requires that the associated person
committing the fraud had the ‘intention of benefiting’
the organisation or its clients. This intention does not
have to be the sole or dominant motivation for the
fraud – their primary motivation may be to benefit
themselves. It is irrelevant whether the organisation
does in fact actually receive any benefit.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 16
CREDIT MANAGEMENT
Territoriality
The offence applies to relevant offences committed under
UK law. Generally, this means that the fraud requires a
direct UK connection, but non-UK companies can fall
within scope.
For example, a non-UK-based company could fall within the
scope of the FTPF offence if an employee of the organisation,
who is based in the UK, commits a relevant qualifying
offence in the UK, or an employee of the organisation, who
is not based in the UK, commits fraud targeting UK victims.
Strict liability
The FTPF offence is a ‘strict liability’ offence. This means
that if a relevant qualifying fraud offence is committed, by
a relevant ‘person associated’, with a ‘relevant body’ (that
it’s a large organisation), then the corporate body has on
the face of it committed the offence. Senior managers in an
organisation do not have to be aware of what the fraudster
has done for the corporate to be guilty of FTPF offence.
WHAT AMOUNTS
TO ‘REASONABLE’
WILL BE JUDGED
BASED ON THE
CONTEXT OF
EACH CASE.
Under ECCTA, an organisation will not be guilty of an
offence if it can prove, on the balance of probabilities, that it
had reasonable procedures in place to prevent fraud, or that
it was unreasonable to expect it to have such procedures. The
onus will be on the organisation to discharge this burden.
What amounts to ‘reasonable’ will be judged based on
the context of each case, considering factors such as the
organisation’s size, nature, and complexity of its activities.
Making preparations
The guidance, which courts will use as a benchmark, sets
out that fraud prevention structures within an organisation
should be guided by six Principles. At a high level, these are:
Top-level commitment. This means ensuring that senior
management is actively involved in fraud prevention efforts.
It includes fostering a culture where fraud is not tolerated,
endorsing anti-fraud policies, allocating resources, adopting
speak-up policies, and leading by example.
Risk assessment. This means evaluating the nature and extent
of an organisation’s exposure to fraud risks, focusing on
employees, agents, and other associated persons. It includes
identifying specific roles and scenarios that present higher
risks and ensuring that the risk assessment is documented
and reviewed regularly.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 17
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FRAUD
Proportionate risk-based fraud prevention procedures.
This means developing and implementing fraud
prevention measures (that respond to the risk
assessment) that are relevant to the identified risks. This
may amount to an ‘anti-fraud policy’, which sets out the
policies and procedures of the organisation to mitigate
the risk of fraud. These procedures should cover various
operational areas, such as procurement, financial
reporting and contractual relationships.
Due diligence procedures. This means conducting
thorough, risk-based, due diligence on all associated
persons. This should include the use of appropriate
technology, such as third-party risk management tools,
reviewing contracts, and monitoring the well-being of
staff to identify those who may be more likely to commit
fraud because of stress, targets or workload.
Communication (and training). This means developing a
training programme to educate employees and other
associated persons on fraud risks, and prevention
measures (such as whistleblowing procedures). It
includes ensuring ongoing communication about the
organisation’s stance on fraud and the consequences of
fraudulent behaviour.
Monitor and review. This means establishing a system
for regular monitoring and review of fraud prevention
measures. It includes detecting attempted fraud,
investigating suspected fraud, and evaluating the
effectiveness of prevention procedures.
Detailed records of all risk assessments, prevention
measures, training programmes, and decisions related to
fraud prevention should be kept. This documentation will
assist in demonstrating compliance and reasonableness
in the event of a challenge of the effectiveness of the
measures put in place to prevent fraud.
The guidance makes clear that whilst existing policies
and procedures may be relevant such as an organisation’s
Bribery Act 2010 policies, or policies it has because it
is regulated by the Financial Conduct Authority, it
will not be a suitable defence to state that because the
organisation is regulated its compliance processes under
existing regulations would automatically qualify as
‘reasonable procedures’ under ECCTA.
Smaller companies
Whilst only ‘large’ organisations are within scope of the
FTPF offence, the guidance notes that the Principles
represent good practice and may therefore also be
helpful for smaller organisation.
It is of course also possible that a currently ‘non-large’
organisation will in future years grow (in number of
employees, turnover, or assets) and therefore qualify
as ‘large.’ Therefore, it is worth all organisations taking
note of changes.
Conclusion
The FTPF offence marks a major shift in corporate
accountability, emphasising the need for robust
fraud prevention measures in large organisations.
Organisations should ensure they thoroughly understand
and implement the principles outlined in the guidance.
To adequately prepare, organisations may wish to seek
legal advice to navigate areas of uncertainty.
As the offence is both new and far-reaching, organisations
should remain vigilant in maintaining and updating
their fraud prevention procedures, documentation, and
training programs.
Sebastian Sayer is a partner, and Gloria Palazzi is
a trainee solicitor, in the financial services team of
Fox Williams.
Background to the offence
As the Law Commission has previously detailed, the
general rule for attributing liability to companies in
English and Welsh criminal law is the ‘identification
principle’. This states that where a particular mental
state is required, only the acts of a senior person
representing the company’s “controlling mind and
will” can be attributed to the company. In practice,
this is limited to a small number of directors and
senior managers.
In recent years, concern has been expressed that
the identification principle does not adequately
deal with misconduct carried out by and on behalf
of companies (and other ‘non-natural persons’). In
particular, some have suggested that it has proved
disproportionately difficult to prosecute large
companies such as banks for economic crimes
committed in their names, by senior managers,
for the company’s benefit. In practice, it can be
much easier to hold a small company to account
for wrongdoing than a large business where
responsibility for decision-making is more diffuse.
In November 2020, the then Government asked the
Law Commission to examine the issue and publish a
paper providing an assessment of different options
for reform. Following a discussion paper, round
table events and a consultation the Law Commission
published a paper in June 2022 examining options
to improve the law to ensure that corporations are
effectively held to account for committing serious
crimes. The paper considered the creation of a new
offence of failure to prevent fraud. This offence was
subsequently created by the Economic Crime and
Corporate Transparency Act 2023.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 18
CREDIT MANAGEMENT
Example of fraud by abuse of position
The payroll department of company A is supposed
to ensure that the company contributes to the
employees’ pension funds every month. However, the
head of the payroll department arranges for some
of these payments to be diverted for other projects
within the company but continues to record them as
payments to the pension fund.
The base fraud is fraud by abuse of position (since
the head of the payroll department is entrusted
with making payments for the employees), and
the associated person is the head of the payroll
department. The intention is to benefit other projects
within the company. Company A could be liable for
the offence under section 199(1)(a) unless a court
decides that it had reasonable procedures in place to
prevent the fraud.
Example of aiding and abetting fraud
Company A is seeking bank lending to purchase new
equipment. Employee C of Company A encourages
one of Company A’s clients (Company B) to make
a statement about its intention to place a series of
orders with Company A if Company A obtains the
equipment. Employee C drafts a letter from Company
B to the bank and gives it to Company B to sign.
In fact, Company B is winding up its operations and
will not be making any such orders. Company B has
committed fraud by false representation (it has made
a statement it knows to be false in order to make a
gain for Company A and has exposed the bank to the
risk of loss). Employee C has encouraged and assisted
Company B to commit the offence. As Employee C
has committed the offence with intent to benefit
Company A, Company A could be liable for the
offence unless a court decides that it had reasonable
procedures in place to prevent the fraud.
ORGANISATIONS
SHOULD REMAIN
VIGILANT IN
MAINTAINING AND
UPDATING THEIR
FRAUD PREVENTION
PROCEDURES.
Example of intended benefits not realised
An investment fund provider promotes investment
in a ‘sustainable’ timber company, knowing that, in
fact, this company’s environmental credentials are
fabricated, and that the timber is harvested from
protected forest. Investors are deceived into placing
funds with the investment fund provider. The base
fraud is fraud by false representation. The intent is to
benefit the fund provider.
The associated person is the relevant member of staff
at the investment fund provider who knowingly
used the false information in the investment fund’s
brochures for clients. The investment fund provider
could be liable under section 199(1)(a) unless a court
determines that it had reasonable procedures in place
to prevent this fraud. The offence applies even if
investment is not actually secured – it is enough that
the fraud was intended to benefit the investment fund
provider.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 19
STANDARDS
“REDUCING THE CHOICE
THAT BUSINESSES HAVE BETWEEN
EITHER GREENWASHING OR
GREENHUSHING IS FAR TOO
SIMPLISTIC’’
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 20
CREDIT MANAGEMENT
GREEN FLASH
AI is causing havoc in relation to the ASA’s ability
to monitor advertising for ‘greenwashing’.
BY JONATHAN RUSH
THE trouble with standards, regulations,
and law is that they need enforcement
and that, in the modern
world, can be difficult.
For a while now the Advertising
Standard Agency (ASA) has been
using AI-assisted collective advert monitoring. And it
appears to be working.
Over the period of 2022-23, the body saw a 30-fold increase
in the number of adverts it has been able to analyse. This,
along with the ASA's new strategy to proactively pursue
so-called ‘greenwashing’ claims, means that businesses
across many sectors are now falling foul of the regulator.
As a result, it’s important that organisations and
businesses understand the heightened risks they face
from increased scrutiny of green claims they make and
also, what they can to do to minimise their exposure. So
what can we expect from the ASA in the Environmental.
Social and Governance (ESG) space?
A new strategy
In April, the ASA published its 2023 Annual Report,
setting out its five-year strategy which relies on AIassisted
collective advert regulation to shift the ASA from
complaints-led investigations to proactive monitoring
and enforcement. This is a significant change, establishing
the ASA as a more visible and dynamic regulator in the
ESG arena.
The Annual Report makes clear that environmental
claims remain a top priority for the regulator.
James Best, Chair of the Committee of Advertising
Practice (CAP), says in the report that perhaps the most
important work in the long term has been concerned with
environmental claims, including work clarifying what
‘green claims’ mean and determining how climate change
and mitigating technologies should be communicated in
adverts.
This is evidenced by the ASA’s increased activity
regarding ESG. In 2023, it introduced new guidelines on
environmental claims in advertising, and in recent years
it has actively investigated and made findings in relation
to a significant number of misleading environmental – so
called ‘greenwashing’ – claims that are considered further
below.
The ASA and AI
In 2023, the ASA introduced its active AI monitoring
tool. The tool uses AI to proactively monitor online
advertising and identify adverts which are most likely to
be problematic for further review. By the end of 2023, the
tool was processing over 500,000 adverts a month and the
ASA says that it contributed to the majority of adverts
which were amended/withdrawn following ASA action
that year.
The tool is being used to pursue the ASA's focus on
environmental claims. The development of the system is
ongoing, so the system's impact will likely continue to
grow, both to enhance the ASA's activities in relation to
environmental claims and to allow it to conduct reviews
in other areas.
This is a significant shift for the ASA, which has previously
tended to focus more on responding to complaints from
consumers and in some cases, competitors. AI is clearly
helping the ASA to adopt a more proactive and strategic
approach, identifying potentially problematic adverts
which have not necessarily been the subject of complaints.
The ASA is not the only regulator rapidly developing its
AI capabilities. For example, the FCA and the Bank of
England are already using AI. The FCA is using tools to
detect, review and triage potential scam websites, and inhouse
synthetic data to assess firms' sanctions screening
systems. The Bank is using AI ‘to support and enhance
[its] capabilities’ including in predictive analytics, and
data analysis. And the PRA is using a cognitive search
tool to identify patterns in unstructured and complex
firm management information.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 21
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STANDARDS
The FCA and ASA often work closely together in targeting
misleading claims. The FCA recently published finalised
guidance on the anti-greenwashing rule which came into
effect on 31 May 2024 and applies to all FCA-authorised
firms. The rule requires that references made to the
sustainability characteristics of a product or service, are
(i) consistent with the sustainability characteristics of the
product or services and (ii) clear, fair and not misleading.
The ASA and ESG
In 2021 the ASA launched its Climate Change and the
Environment project to respond to the climate crisis and
to ensure that environmental claims made in advertising
were not misleading or irresponsible. Since then, the
ASA and CAP have issued substantive guidelines for
businesses on environmental advertising and the ASA has
significantly increased its activity in this area.
Consider its action in relation to major airlines as a
number of adverts were banned. They included a Virgin
Atlantic advert which stated: ‘Virgin Atlantic’s Flight
100 will … become the world’s first commercial airline to
fly transatlantic on 100% sustainable aviation fuel’. They
also included an Air France-KLM advert which included
the claim ‘…Air France is committed to protecting the
environment: travel better and sustainably’.
In overview, the ASA found that each advert gave a
misleading impression of the advertiser's environmental
impact, and that the advertisers either could not provide
any evidence to back up the claim, or had omitted material
information regarding the claim which would have been
required for the consumers to make an informed decision,
or for them to properly understand the claims being made.
Accordingly, the advertisers were required to retract the
adverts (or, in the case of Virgin Atlantic, ensure that
future adverts contained qualifying information which
explained the environmental impact to customers).
Further claims
While the airlines have been targeted the ASA has also
made similar findings relating to environmental claims
across a variety of other sectors such as fossil fuels,
financial services, and household goods.
And there are several examples including:
Fossil fuels: A paid-for online display advert for Repsol, a
global energy company, featured several images of leaves
with text that stated: ‘At Repsol, we are developing biofuels
and synthetic fuels to achieve net zero emissions’. The ASA
concluded that the advert omitted material information
and was misleading, failing to explain that it was part of a
wider plan to achieve net zero by 2050.
E-cigarettes: Adverts for the vaping company Elf Bar after
it used the slogan ‘recycling for a greener future’. The ASA
felt that this was misleading because of the environmental
damage of discarded vapes.
Food: Ads for plant-based milk brand Oatly, for making
claims, such as ‘Oatly generates 73% less CO2e vs. milk,
calculated from grower to grocer’. The ASA said the
advert was misleading because Oatly based the claim on
comparing one of its products, Oatly Barista Edition,
but consumers would understand the claim to include all
Oatly's products, which was inaccurate.
Cars: BMW ads claiming that its electric vehicles were
‘zero-emission’. The ASA disagreed, noting that the models
produced carbon emissions during their manufacture, as
well as when recharging using electricity generated from
fossil fuels.
Risks to businesses
As with any adverse finding, a ruling from the ASA can not
only have financial consequences for a business in terms of
wasted costs when an advert is required to be amended or
withdrawn but also cause reputational damage.
Falling foul of the ASA also puts businesses at risk of
coming within the crosshairs of the Competition and
Markets Authority (CMA).
Businesses should be aware that, from this month (April
2025), the CMA will have significant new powers to
investigate and enforce consumer protection laws pursuant
to the Digital Markets, Competition & Consumers
Act 2024 (DMCCA). Before the CMA had to initiate
lengthy court proceedings to just establish a breach, but
the DMCCA will allow the CMA to directly impose
fines of up to 10% of global annual turnover if it finds
consumer law has been infringed, including in respect
of deliberately misleading consumers about products or
services. Individuals associated with the breach could also
be sanctioned.
This marks an important shift from a primarily selfregulatory/judicial
system of enforcement to a full
administrative regime similar to the UK's existing
approach to competition law enforcement. Whereas
the CMA’s current limited consumer powers arguably
encourage it to accept voluntary settlements to resolve
concerns, it will now have the arsenal to more aggressively
pursue and sanction potential infringements.
Comparing like for like
Where the ASA might be characterised as adopting a ‘high
volume’ approach, scrutinising a large number of adverts
across a wide range of sectors, the CMA tends to be more
selective. Typically, it will focus on a smaller number of
high impact investigations, often with a view to setting
precedents which it hopes will influence the wider market.
That said, when deciding which cases to pursue, the CMA
will often look at areas where the ASA has already found a
significant level of non-compliance – hence the danger that
an adverse ASA ruling may ultimately draw the attention
of the CMA (or other regulators such as the FCA).
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 22
CREDIT MANAGEMENT
including possible mass consumer claims. Indeed, we have
already seen significant group litigation being brought
against vehicle manufacturers over the diesel emissions
scandal. Businesses must therefore give careful thought to
how to mitigate these risks.
Faced with these risks, some businesses may be tempted
to steer clear of any sort of green claim – an approach
which has been described as ‘greenhushing’. However, this
risks chilling the genuine and legitimate aspirations of
most businesses to pursue their sustainability ambitions.
Many have a good story to tell – and as the ASA itself has
noted, “reducing the choice that businesses have between
either greenwashing or greenhushing is far too simplistic.
Impactful and informative green claims benefit consumers
because they enable them to make more responsible
choices.’’
Checking claims
Stepping back, what regulators are asking business to do is
arguably no different in principle from what they expect
with regard to any type of marketing claim, namely that
it should be supported by adequate evidence; and not be
expressed in a way that gives a misleading impression,
particularly when it comes to the business' overall impact
on the environment.
A further contrast with the ASA is that while the latter
focusses on bringing infringing behaviours to an end,
the CMA's new consumer powers will allow it to impose
penalties for past conduct – thus substantially increasing
the risks to business from making green claims which are
later found to be misleading. Indeed, the CMA's latest
action in relation to the fast fashion sector – where it has
issued guidance on what it regards as misleading – seems
to be laying the groundwork for enforcement action under
its new powers if the relevant brands fail to respond.
Finally, it's also worth noting that the CMA has identified
sustainability as an important objective not only for its
consumer protection function but also in relation to its
remit in the areas of competition law, merger control and
market investigations, where it has enjoyed significant
enforcement powers for some time.
And in addition to regulatory risks in the UK, the EU
is pursuing a number of measures intended to combat
misleading environmental claims about products and
services aimed at consumers.
Protecting the organisation
There is also a clear risk to businesses that the ASA’s
(and the FCA's and CMA's) focus on the ESG space may
encourage costly and reputationally damaging litigation,
High carbon-emitting business may be particularly
concerned by this last point, but as the ASA has
acknowledged, it should not mean that green claims are
completely off the table; on the contrary, it notes that
some businesses have managed to strike the right balance
‘through the inclusion of straightforward, prominent copy
in ads that acknowledges the less-climate-positive aspects
of their activities, that indicates how early in their journey
they are, or that provides summary details of their future
planned activities. Such copy does not have to dominate
ads, but it must not be hidden away’.
All of this said, the current focus on greenwashing
means that it is essential to ensure that such claims are
thoroughly verified and that relevant individuals in the
business (including at the highest levels) are satisfied
with the accuracy of the claims. In particular, absolute
environmental claims (for example claims that a product
is ‘100% recyclable’ or ‘environmentally friendly’) must
be capable of substantiation or, alternatively, statements
should be expressed in appropriately qualified terms.
Summary
To conclude, it’s perfectly clear that while organisations
and businesses are entitled to advertise their goods and
services, they need to do so with compliance uppermost
in their minds. The regime of the past where enforcement
relied on reporting has gone. Now the threat of action
comes from the proactive use of technology to markedly
step up what regulators can do.
Jonathan Rush is Knowledge Counsel at Travers Smith.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 23
VIEW FROM THE SEA
CLOCKED
OFF
Are we in danger of losing our way at work?
BY DAVID ANDREWS
A
long road trip through France
and Belgium at the start of the
year saw me stopping off with old
friends in the Dordogne region.
Of a similar vintage, my chums
have retired to enjoy la vie
Francais, glug plenty of fine wine, and feast on the local
fromage. They have one of those epic, beautiful houses
with plenty of outhouses for gite letting, a gorgeous pool
and their own vineyard. All for £500,000, which is broadly
what you’d pay for a one-bedroom flat in a challenged part
of south London.
Winters are harsh but come the spring it’s a lovely part of
the world. The perfect spot for a game of tennis and a glass
or two of Kir Royale. Not bad, eh? But there is a fly in the
ointment. Or maybe that should be a bluebottle.
My friend’s son, now 26 and educated to a high standard,
lives in the UK with his partner and has never had a job.
And I mean never. It’s a cause of much concern, distress
even, to my old mates. The young man is able bodied.
Intelligent. With a good degree. But he has chosen, like
literally millions of others of his generation (Z) to eschew
work and instead live off benefits. Which as it happens
are not bad.
What does he tell his civil servant interrogators when he
has a ‘review’ as to whether he will continue to qualify for
the free handouts? Well, a range of ‘issues’. Readers will be
familiar with most of them as this scenario is so prevalent
in the media.
Jeewhizz. If I had a tenner for every time I’ve heard these
incredibly annoying cards being played, I’d be off to the
Dordogne and a lovely second home myself. It’s such a
wind up.
Labour shortages
Government statistics show that there were approximately
670,000 unemployed people aged between 16 and 24 in the
third quarter of last year (2024). That’s 98,000 more than
in 2023, or to give more perspective, the highest recorded
number since age group records started in 1992.
The thing is, there’s plenty of work out there. Employers
are crying out for young labour but struggling to attract
quality applicants. It’s not just our youngsters who are
work-shy. Older beneficiaries of our generous benefits
system are creaming it in. So out of a potential UK adult
workforce of 25 million, around nine million are stay at
homers. They are taking the benefits – not paying any tax
– and ergo not contributing materially to our society in
any meaningful way to keep the wheels turning.
And we can’t afford it. Simple as that.
When I was 16 I left school and for several years
worked a host of menial jobs until finally getting
A levels and going to university in my 20s. Up at
5-00 am to drive a dumper truck in 1973 on a sprawling
building site in High Wycombe, Bucks. Try turning a
frozen solid dumper truck starting handle (it was a long
time ago) on a freezing February morning. And then
loading it with wet cement and bricks. At 7-00 in the
morning in minus conditions.
I did all that. No claims for mental health issues and the
like. Just very, very cold. And I gave my mum a portion
of my wages for my keep every week. It’s how it was
back then. No obesity. An NHS which worked just fine.
Broadly full employment. And no playing of these bizarre
contemporary maladies.
On the road trip I got myself up to the east of Belgium,
into the Ardennes Forest near a town called Bastogne.
Older readers may recognise the name. It’s where some of
the most vicious fighting of WW11 took place during the
so called battle of the Bulge.
Last gamble
Hitler’s last throw of the dice in December 1944 was to
send many divisions of crack Panzer squads and hordes
of infantry through the Eiffel region and into Belgium in
the hope of breaking the Allied supremacy in post D-Day
France, Holland and Belgium. The fighting raged around
Bastogne until the end of February 1945. Many, many
young American GIs lost their lives in the dreadful cold
and bitter fighting that winter. Most were aged around 20
years old. Generation Z-ers if you like.
I stood in various foxholes in Bois Jacques, the woodland
area seven kilometres from Bastogne where Easy Company
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 24
*
CREDIT MANAGEMENT
MANY YOUNG AMERICAN GI’S LOST
THEIR LIVES IN THE COLD AND BITTER
FIGHTING THAT WINTER. MOST
WERE AGED AROUND 20 YEARS OLD.
GENERATION Z-ERS IF YOU LIKE.
of the 101st paratroopers held their part of the front line.
Shelled relentlessly and repelling endless advances by
enemy tanks and infantry, those young men fought and
died in their foxholes. They did their job.
I thought of this sacrifice, unquestioning, it’s what we’ve
been trained to do. Etc. And I thought of my old mate’s
26-year-old son who had never worked, on his cushy
benefits. And I thought of the sacrifice that long ago
generation had made. For us. And it does not seem fair.
Innocent times
I cannot quite believe it’s been 37 years since I pitched
up as a young business reporter for CM. In those days
the title was based in the sleepy Lincolnshire hamlet of
Easton on the Hill. I would motor up from my north
London flat in a battered Alfa Romeo and spend a few
nights in a Stamford b ‘n b. No Air BnB in those days of
course.
A fellow reporter, Anthony Levy, became a good friend.
We spent a fair bit of time in the many outstanding
Stamford hostelries. Our editor, Richard Smith, was
a fine and highly principled journalist who taught me
a heck of a lot. We had some great laughs in what now
seems a far more innocent time. The pre mobile/social
media/internet days, when the desk telephone was our
only hotline to the world.
And Sir Alan Sugar’s early Amstrad desk top PCs glowed
a Space Invaders green in our compact, smoke-filled
newsroom. Both of my colleagues have sadly long since
departed this world and I’m not getting any younger. But
I don’t do the ‘R’ word and continue to write and consult
for my modest PR business.
All things must pass, however, and new blood flows
through any organisation rightly recognising that the
new stage is for the young. Through my years on national
newspapers and then building a financial PR firm there
have been endless challenges – but I would never have
traded places with anyone else.
It’s a cliche I know… but hard work and application does
pay off. But you have to do the leg work.
Author: David Andrews is a freelance jounalist.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 25
FINANCE
ARTIFICIAL
REALITY
Building and Integrating AI Models in the
Financial Services Sector.
BY MARDI MACGREGOR AND ROMANS VIKIS
Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 26
CREDIT MANAGEMENT
AS the digital landscape
continues to evolve, artificial
intelligence (AI) represents a
transformative force within
the financial services sector.
By automating routine and
tedious tasks, providing
predictive analytics, enabling algorithmic trading,
and facilitating more effective risk management, AI
has multiple potential applications in the industry.
In recent months, the Bank of England (BoE) and
Financial Conduct Authority (FCA) have continued
to focus on AI in financial services, with the BoE
stating that appropriate regulatory responses are
required to negate the potential implications of AI
on financial stability, and the FCA launching the AI
Input Zone to gather stakeholders' views on current
and future uses of AI in UK financial services, as well
as the financial services regulatory framework.
AI in financial services is firmly on the UK financial
services regulators’ agenda and accordingly, there are
key considerations that firms should take into account
when building and integrating AI models in the
financial services sector to ensure they realise the full
potential of AI while minimising the risks associated
with its adoption.
Key considerations
Whilst the development and utilisation of innovative
AI-powered technologies are an exciting prospect for
financial services firms, data scientists and machine
learning engineers alike, the utility (and therefore, the
monetary value) of AI is dependent on the extent to
which it can be lawfully used.
In a joint discussion paper (DP5/22) from the FCA,
BoE, and the Prudential Regulation Authority (PRA)
in October 2022, the primary drivers of AI risk in
financial services were identified as relating to three
key stages of the AI lifecycle – data, models, and
governance, each of which are considered below.
The importance of data use
From sourcing large amounts of data and creating
datasets for training, testing, and validating, through
to the continuous analysis of data once the AI system
is deployed, the safe and responsible AI adoption
in UK financial services is underpinned by the use
of high-quality data. Financial services firms must
therefore consider the quality of their data.
Data quality and assurance
Poor quality or inappropriate data can compromise
any process that relies on it. The way in which data is
sourced and aggregated can impact the overall quality
of the data, and the intended outcome of a model. The
UK’s current regulatory framework aims to address
these specific risk components of the data lifecycle.
For example, the Basel Committee on Banking
Supervision has published various principles (the PRA
expects banks to adhere to these principles) aimed
at strengthening prudential risk data aggregation
by ensuring the accuracy, integrity, completeness,
timeliness, and adaptability of data. The PRA’s current
rules also require insurers to have internal processes
and procedures in place to ensure the completeness,
accuracy, and appropriateness of the data used in the
calculation of their technical provision.
Data sourcing is a critical consideration not only
because it will fundamentally shape the AI system,
but also because of the potential liability that may
arise if that data was sourced through inappropriate
means. This means ensuring that any data sourced is
compliant with relevant data protection regulations
and intellectual property rights, as well as having the
necessary permission to use it, to avoid possible civil
litigation.
AI-POWERED
TECHNOLOGIES
ARE AN EXCITING
PROSPECT FOR
FINANCIAL SERVICES
FIRMS, DATA
SCIENTISTS AND
MACHINE LEARNING
ENGINEERS ALIKE
Data privacy and security
Ensuring data is protected from malicious threats
such as unauthorised access, theft, and corruption is
crucial, and firms must ensure that data privacy and
anti-money laundering / counter-terrorist financing
regulations are complied with when sourcing and
utilising data in the development of AI. The UK's
Information Commissioner’s Office has updated its
guidance on AI, focusing on data protection impact
assessments, transparency to data subjects, and
minimisation of data usage. Meeting the core principle
of the GDPR – that only the minimum amount of data
needed to fulfil the purpose of processing is utilised –
can often be at odds with the large volumes of data
required to train AI systems. In order to comply with
this obligation, the risk management function of the
AI project must implement practices that are designed
to ensure that data minimisation is considered from
the initial design phase. Where an entity outsources
the AI production to a third party, this consideration
should form part of the due diligence process.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 27
continues on next page >
FINANCE
Data architecture,
infrastructure, and resilience
Firms must have strong data architecture and risk
management infrastructure under the FCA and PRA’s
current rules and guidelines to ensure AI technologies
are resilient against operational disruptions and data
quality issues. This includes having processes to manage
data architecture and resilience effectively, ensuring that
even in times of data breaches or system failures, the AI
models remain functional and reliable.
Robust AI development
When developing AI models, the joint discussion
paper highlights that firms must ensure the models are
compliant with a number of requirements.
Robust
AI models need to be resilient to errors and adaptable to
unforeseen changes. Firms must consider the possibility
of model drift (i.e., where the model’s performance
deteriorates over time as the data distribution changes).
Models should be periodically retrained and validated to
maintain their performance.
Fair
AI models must be built to ensure that they are fair to
all groups of people, regardless of their gender, race, or
other characteristics. Firms should ensure that they do
not use biased data or introduce biases unintentionally
while building the models. They must also consider the
possibility of unintended consequences and monitor
the models’ performance to ensure that they are not
perpetuating existing biases.
Diversity and inclusion continues to be a top regulatory
priority with the PRA and FCA consulting on measures
to boost diversity and inclusion in the financial services
sector last year. Firms will need to ensure that AI models
comply with current and upcoming regulatory rules and
guidance in this area.
Firms must also ensure that they are delivering good
customer outcomes when developing and using AI,
for example by providing unbiased, clear, and accurate
information to customers, and safeguarding their interests
by generating decisions that are fair and justifiable.
Techniques such as algorithmic fairness, where the model
is continuously tested for unbiased decision-making, can
be employed to promote fair AI systems.
Explainable
AI models must be explainable to stakeholders. Firms
should ensure that transparent models are used and
provide clear explanations for the decisions made by the
models. This may be a challenge for firms, as AI models
(particularly generative AI models) may be difficult to
explain (both in terms of how it works and the reasons
for its outputs). However, techniques such as using whitebox
models or creating explainability frameworks that
outline how decisions are made by the AI system can help
in achieving transparency.
Model governance
The joint discussion paper also highlights that governance
is a critical factor in ensuring the safe and responsible
adoption of AI in the financial sector. A number of key
recommendations were provided in the paper for AI
governance.
Accountability
Firms should ensure that they have clear accountability
structures in place for the AI models they develop, and that
the roles and responsibilities of the stakeholders involved
in the AI lifecycle are clearly defined and communicated.
The PRA’s and FCA’s existing rules and guidance around
the Senior Managers and Certification Regime (SMCR)
emphasise senior management accountability and
responsibility and are relevant to the use of AI. At present,
there is no dedicated senior management function (SMF)
for AI, with technology systems currently being the
responsibility of the SMF24 (Chief Operations functions)
and the overall management of the risk controls of a
firm being the responsibility of the SMF4 (Chief Risk
function). Therefore, a key consideration for firms is who
should be responsible for the use of AI within the firm.
AI MODELS IN THE
FINANCIAL SECTOR
OFFER SIGNIFICANT
OPPORTUNITIES
FOR FINANCIAL
INSTITUTIONS TO
REDUCE COSTS
Risk management
Firms should have a robust risk management framework
in place for the AI models. They must ensure that they
identify and assess the risks associated with the models
and implement appropriate risk mitigation measures.
Whilst the joint discussion paper recognises that the use
of AI may, in some cases, be used to minimise risk and
increase stability for a firm, it may also have the effect of
amplifying many of the existing risks to financial stability
in the financial services sector more generally. For
example, the use of similar datasets and AI algorithms
may create uniformity across models and approaches
at multiple firms, which could amplify behaviour and
lead to herding in certain use cases, such as algorithmic
trading, or increase the potential for systemic risk and
market disruptions.
Board composition,
and engagement
Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 28
CREDIT MANAGEMENT
There may be a lack of understanding of the
challenges and risks arising from the use of advanced
technologies at firms’ senior management and board
levels, both individually and collectively, leading to
a skills and engagement gap and a risk of ineffective
governance. There are requirements and expectations
on firms to address this skill gap, including the PRA’s
expectations that boards should have the diversity of
experience and capacity to provide effective challenge
across the full range of the firm’s business and boards
should pay close attention to the skills of its members;
and the FCA requirements for issuers to publish
information on board diversity policies in their
corporate governance statement.
Future regulation of AI
In October 2023, the FCA, PRA and BoE published
a feedback statement to their joint discussion paper.
Whilst this feedback statement summarised the
responses received in relation to the discussion paper,
it did not include policy proposals, nor did it signal
how the UK supervisory authorities are considering
clarifying, designing, and/or implementing current or
future regulatory proposals on this topic.
Nevertheless, there were a number of key points
made by respondents. It was noted that a regulatory
definition of AI was not seen as beneficial due to the
rapid evolution of AI technologies. Also, there was
a preference towards principles-based or risk-based
approaches rather than specific AI definitions.
Industry engagement was seen as crucial, with
initiatives like the AI Public Private Forum being
valuable. Similarly, coordination and alignment
between domestic and international regulators was
recommended to reduce complexity.
An emphasis on consumer outcomes, particularly
fairness and ethical considerations was valued while
concern was raised over the increasing use of thirdparty
AI models and the need for regulatory guidance.
This said, firm governance structures and frameworks
such as SMCR were deemed sufficient to handle AI
risks. In October 2024, Sarah Breeden, BoE Deputy
Governor for Financial Stability, delivered a speech
addressing the implications of AI on financial stability.
As noted in Breeden’s speech, the increasing power
and use of AI, particularly generative AI, poses
significant implications for financial stability,
requiring appropriate regulatory responses. She also
noted that generative AI models are distinct due to
their autonomous learning and evolving capabilities,
with outputs that are not always interpretable or
aligned with societal goals. AI is expected to bring
considerable benefits to productivity and growth.
However, regulators must develop frameworks to
manage associated financial stability risks.
The speech highlighted two main regulatory concerns.
At the microprudential level, technology-agnostic
frameworks are needed to mitigate risks as AI
adoption increases. And at the Macroprudential level,
it is necessary to be vigilant about systemic risks and
have evolving stress tested frameworks.
The Financial Policy Committee (FPC) is scheduled
to publish its assessment of AI's impact on financial
stability early in 2025. This assessment will include
strategies for monitoring the evolution of potential
risks associated with AI in financial services. The
FPC aims to understand and mitigate risks such as
interconnectedness and trading behaviours influenced
by AI.
FCA’s AI Input Zone
In November 2024, the FCA launched the AI Input
Zone to gather stakeholders' views on current and
future uses of AI in UK financial services, as well as the
financial services regulatory framework. This initiative
aims to support safe and responsible innovation,
promote sector growth and competitiveness, and gain
practical insights into AI usage. The AI Input Zone,
part of the FCA’s AI Lab, invites diverse market
participants to share their perspectives and participate
in shaping the FCA’s future regulatory approach.
The initiative is an evidence-gathering effort to
understand transformative AI use cases and identify
opportunities for innovation. Stakeholders were
encouraged to express their views about current and
future uses of AI in UK financial services by the end
of January (2025).
Conclusion
The development of AI models in the financial
sector offer significant opportunities for financial
institutions to reduce costs, increase efficiency, and
improve customer experiences. However, there are
risks associated with its adoption such as hallucinations
and unpredictable behaviour, opaqueness, and a
firm’s lack of control over the foundation models
used in Generative AI (such models typically being
built and trained by third parties). As the use of
generative models (such as ChatGBT, Llama, BERT
and RoBERTa) increases, it is likely that the UK
regulator’s scrutiny of this technology will too.
At a minimum, firms must ensure that they comply
with data protection regulations, have permission
with regards to the data being fed to the AI system,
build robust, fair, and explainable AI models, and
implement appropriate governance frameworks, and
should keep up to speed with further guidance released
by the regulators in this area. By doing so, firms
may be able to realise the full potential of AI while
minimising the risks associated with its adoption.
Author: Mardi MacGregor is a partner, and Romans Vikis
is an associate, at Fox Williams LLP.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 29
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T: +44 (0)2073 875 868 - London
T: +44 (0)2920 495 444 - Cardiff
W: Menzies LLP.co.uk/creditor-services
Bottomline Technologies (NASDAQ: EPAY) helps
businesses pay and get paid. Businesses and banks
rely on Bottomline for domestic and international
payments, effective cash management tools, automated
workflows for payment processing and bill review
and state of the art fraud detection, behavioural
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help our customers by making complex business
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T: 0870 081 8250
E: emea-info@bottomline.com
W: www.bottomline.com/uk
Genius provides solutions designed to enhance your
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our team have decades of operational experience in
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As a global outreach partner our technology
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• Streamline Collections, Payments & Asset
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E: sales@geniusssl.com
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Transform your Accounts Receivable with
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Building on our mature and hugely successful
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and ROI are inevitable for our customers that also
have an active input into our product development
and evolution.
T: 01235 856400
E: info@credica.co.uk
W: www.credica.co.uk
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 30
Each of our Corporate Partners is carefully selected for
their commitment to the profession, best practice in the
Credit Industry and the quality of services they provide.
We are delighted to showcase them here.
They're waiting to talk to you...
My DSO Manager is an intelligent SaaS AR and
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Due to its inventive in-house IT teams and their tight
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T: +33 (0)458003676
E: contact@mydsomanager.com
W: www.mydsomanager.com
Court Enforcement Services is the market
leading and fastest growing High Court Enforcement
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over 100,000 High Court Writs and recovered more
than £187 million for our clients, all debt fairly
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TCN is an industry leader in call centre technology
with offices around the world including, the United
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T: +44 (0) 800-088-5089
E: spencer.taylor@tcn.com
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perfect blend of solutions to help you engage offline,
online or the perfect blend of the two.
Top Service Ltd. The only credit information and
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stay one step ahead and experience less debt and
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analytics. We help clients make smarter decisions
and drive resilience by bringing together millions
of data sources into a globally consistent view,
underpinned by our D-U-N-S number.
T: 01761 416311
E: info@cfh.com
W: www.cfh.com
T: +44 1527 503990
E: membership@top-service.co.uk
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TOP SERVICE
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E: hello@dnb.com
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Key IVR provide a suite of products to assist
companies across Europe with credit management.
The service gives the end-user the means to make a
payment when and how they choose. Key IVR also
provides a state-of-the-art outbound platform
delivering automated messages by voice and SMS.
In a credit management environment, these services
are used to cost-effectively contact debtors and
connect them back into a contact centre or
automated payment line.
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provider of business payment solutions, providing
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By creating an additional lever to help support
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proud to be an innovator in the business payments
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STA International is a leading credit management
provider, offering debt recovery, outsourced credit
control, address tracing, and legal debt recovery
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W: www.stainternational.com
Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 31
COUNTRY FOCUS
on Turkey
Border Crossing
Turkey is at a crossroads in more ways that none.
THE FOUNDING FATHER OF
THE MODERN TURKISH STATE,
THERE’S PLENTY TO KEEP A
VISITOR INTERESTED.
Tu
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 32
CREDIT MANAGEMENT
rkey
member
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 33
WE could open and
close a country profile
on Türkiye, formerly
known as Turkey, very
quickly. It’s an emerging
country with an uppermiddle-income
that sits
at the crossroads of Europe, Asia and Africa with a history
that cannot be ignored.
Known for Istanbul and sights such as Grand Bazaar and the
Blue Mosque, ancient sites such as Pamukkale, Hierapolis
and Ephesus, tulips under the Ottomans (no, they didn’t
originate in Holland), carpets and rugs, a unique cuisine,
and Mustafa Kemal Atatürk – the founding father of
the modern Turkish state, there’s plenty to keep a visitor
interested.
Steeped in History
Türkiye’s history goes back several millennia to well before
the founding of the Turkish Republic in 1923. Originally
a nomadic people from Central Asia, Turkish peoples
established several empires such as the Seljuk and Ottoman
Empires. The former can be dated to between 1037 and
1194, and the latter to 1299 until 1922. The Ottomans took
Constantinople – now Istanbul – in 1453 to become a
dominant world power with lands encompassing Anatolia,
North Africa, southeastern Europe, parts of the Arabian
Peninsula and Persian Gulf, modern day Iraq, and portions
of the Caucasus.
With a religiously and ethnically diverse population it was
only a matter of time before the Ottomans lost territory
from the 17th century. And with numerous national groups
within the empire, slow economic and technological
progress, and an ill-fated alliance with Germany during
World War I, the empire eventually collapsed.
Indeed, it was Mustafa Kemal (Ataturk) who united
disparate Turkish forces against foreign occupation of
Turkish lands. On forming the Turkish Republic in 1923,
Ataturk instituted sweeping reforms that made society
along the lines of a westernised parliamentary democracy.
He ordered the conversion of the Turkish alphabet from
Arabic to Latin script, encouraged European dress, and
incorporated German, Swiss, and Italian law codes into
Turkish law.
It’s no surprise then that this Western orientation led to
Türkiye being a charter member of the United Nations, a
of NATO since 1952, and seeking EU membership.
continues on next page >
COUNTRY FOCUS
Country demographics
According to 2024 data from the Turkish Statistical
Institute, the population is currently around 85.6m.
Chart data from Statista shows a flattish population
with 9.77m in 1800 14.1m to in 1924. But from there on
the rise was and has been exponential with figures of
21.41m in 1950, 43.98m in 1980 and 72.33m in 2010 and
onwards to where it is now.
Data from the European Commission, updated
in November 2023, notes that 50.2% of the total
population is male, and 49.8% is female. In 2018, the
15-64 age group (working age) population increased
by 1.4% compared to the previous year to 67.8%. The
proportion of the 0-14 age group - the child age group -
declined to 23.4% , and those aged 65 and over increased
to 8.8%. Accordingly, the population pyramid for the
country looks very much like a tear drop – narrower
at the bottom, cylindrical to age 54 and tapering to
the top.
The CIA World Factbook reckons, using 2016 data,
that Türkiye is quite homogenous with 70-75% being
Turkish, 19% Kurdish, and 6% -11% being ‘other’. It
follows that Turkish is the official language while
Kurdish and other languages are also spoken.
The country
Officially the Republic of Türkiye, the country is
mainly sited in western Asia with a small part set in
southeastern Europe. The Republic of Turkey, in 2022,
via the UN, changed its spelling to Türkiye.
Sitting astride the Bosphorus Strait, a 19-mile
waterway that connects the Black Sea to, effectively,
the Mediterranean, Türkiye borders a number of
countries. There’s Georgia, Armenia, Azerbaijan,
and Iran to the east; Iraq and Syria to the south; and
Greece and Bulgaria to the west.
With a land area of 769,632 km2, Türkiye is placed
36th in the world, just behind Mozambique but above
Chile. As before, the UK is 78th with 242,741 km2.
It’s topography is variable with semi-arid plateau
and basins in Anatolia that see little rainfall, and
mountains; Black Sea forests with mountains, high
humidity and rain; and land and natural lakes along
the coastlines of the Mediterranean and Aegean that
see hot summers, mild and wet winters, and not
unsurprisingly, fertile soils.
As to where the population lives, the CIA says
that 77.5% of the population is urbanised with the
most densely populated area being found around
the Bosporus in the northwest where 20% live in
Istanbul. The CIA notes too that with the exception
of Ankara, urban centres remain small and scattered
throughout the interior of Anatolia; an overall pattern
of peripheral development exists, particularly along
the Aegean Sea coast in the west, and the Tigris and
Euphrates River systems in the southeast. In numbers,
15.84m live in Istanbul, 5.39m in Ankara – the capital,
3.08m in Izmir, 2.08m in Bursa, 1.83m in Adana, and
1.8m in Gaziantep.
Growing economy?
Türkiye’s economy is considered by the World Bank
and IMF to be the 17th largest in the world with a
GDP of $1.02tn in 2023. In 25 years, the economy has
grown somewhat – from $274.29bn in 2000, $776.97bn
in 2010, a drop to $720.34bn in 2020, to an estimated
$1.12bn in 2024.
But if we look at the World Bank’s chart for Türkiye’s
annual growth rate from 1961 to date, we see a
compressed ECG recording for a patient needing life
support. Just looking at the period from 1983 to 2023
we see a wild sawtooth set of peaks of up to 10%% and
troughs of up to negative 6%. The 2023 rate was 5.1%.
As for inflation, Türkiye cannot be classified as a low
inflation economy. The 1970s recorded rates between
7.92 and 63.54%, a peak of 94.26% in 1980, rates of
40-60% in the 1980s, 105.22% in 1994, a ‘rapid’ drop to
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 34
CREDIT MANAGEMENT
x The Grand Bazaar in Istanbul is one of the largest
and oldest covered markets in the world, with 61
covered streets and over 4,000 shops on a total area of
30,700 m², attracting between 250,000 and 400,000
visitors daily.
equally divided between the children’. Consequently,
nearly two-thirds of Turkish farms are less than
five hectares in size. It added that ‘97% of Turkish
farmers reported diminishing harvests and yields due
to climate change-related impacts’. This is partly a
function of open channel irrigation.
Even so, Türkiye is a major producer of wheat, sugar
beets, milk, poultry, cotton, tomatoes, and other fruits
and vegetables, and is the top producer in the world
for apricots and hazelnuts. It also produces cherries
and figs.
Automotive
In 2023 Türkiye produced some 1.4m vehicles which,
says the Turkish government, puts the country into
third place in terms of European production (first if
only commercial vehicles are counted). Of the 1.4m
units, the Daily Sabah reported in January 2024 that
953,000 were cars.
More than 30 of the top 100 global suppliers have
facilities in Türkiye including Pirelli, Continental,
Bosch and Denso.
Statista states that the Turkish automotive industry
has been the export champion of the country for nearly
the last two decades. After the industry recovered
from the pandemic, the country’s automobile exports
increased …and peaked at $35bn in 2023. Indeed, in 2023
it’s reckoned that around 663,000 units were exported.
8.6% in 2004, a ‘stable’ 6-10% from 2005 to 2017, and an
uptick to a peak 72.31% in 2022 when President Erdogan
lowered interest rates to attempt to reinvigorate the
economy.
Business sectors
Agriculture
The Turkish Government has stated that agriculture
employed almost 18% of the country’s working
population and accounted for 6.5% of the country’s
GDP ($58.5bn) in 2022.
The US International Trade Administration said, in
2024, that over half the country consists of agricultural
land. Statista clarifies the point and reckons that
the size of the total agricultural land did not show
significant changes in Türkiye from 2010 to 2023. After
peaking in 2010 at 24.4m hectares, figures decreased
slightly over the years and reached roughly 24m
hectares in 2023. However, Climate Scorecard has
warned that the average farm size in the country is
decreasing through inheritance law, ‘as land should be
However, there are headwinds as noted by AGBI.
com. It wrote in September 2024 that domestic
manufacturers are facing stiff competition from
imports and grappling with 'sky-high interest rates’.
Production of most commercial vehicle types fell by
between 40 and 51%, partly due to the economy and
private banks charging 55% or more interest on loans.
Overall, at the end of 2023, Türkiye's automotive sector
employed 60,619 workers according to data from the
Automotive Manufacturers Association.
Defence and aerospace
This is an important sector for Türkiye. Mordor
Intelligence detailed that in 2022 military spending
was $15.4bn. According to the Defence Industry
Manufacturers Association, in 2022 Türkiye’s defence
and aerospace industry sales reached $12.2bn along with
an increase in spending on research and development
to $2.1bn from $1.6bn from 2021.
The sector is, however, fragmented. Mordor states that
the country is to enhance its domestic manufacturing
capabilities, especially as it was kicked out of the USled
F-35 programme for buying a Russian made air
defence system.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 35 continues on next page >
COUNTRY FOCUS
Research and Markets, in its forecast to 2027, notes
that the sector and saw total revenues of some
$42.67bn in 2022 on production volumes of 145.8bn
metric tons. The sector has grown considerably
since 2010, according to ceicdata.com reporting
data from the Federal Ministry Republic of Austria.
Back then it produced some 98.7bn metric tons. But
by 2021 that had grown to 146.02bn metric tons.
The sector may grow further still given that, as
aa.com.tr reported in January 2024, that ‘Türkiye has
substantially increased its financial commitment to
the mining sector this year, elevating the budget by
34% to 106bn liras and marking a milestone for the
industry's growth’. It added: ‘Forty-seven miningrelated
projects projected are due to receive funding
in the current fiscal year’.
Cappadocia is a region in central Turkey, known
for its unique landscape of ``fairy chimneys'' and other
rock formations. The area is particularly famous for its
hot air balloon rides, which offer stunning views of the
region's towering rock formations, valleys, and caves.
As for military exports, defenceturkey.com says that
the Gulf and Middle East are crucial export markets
for the Turkish defence and aerospace sector. It
reported that in 2023, Türkiye exported 230 types
of defence and aerospace products to 185 countries.
This it said, is ‘due to its NATO-standard high-tech
product range, competitive pricing, and openness to
technology transfer’.
On the civilian side, the Government notes that there
were 668 civil aircraft that carried 214.2m passengers
in 2022 which produced a turnover of $35.8bn in 2022.
Considering that passengers numbered 34m and
turnover stood at $2.2bn in 2004 it’s easy to see that
tourism has expanded.
Mining and metals
The Turkish Government reports that mining and
metals is another key sector for the economy.
Türkiye has 70 different types of natural resources
and is actively involved in the international trade of
60 of these minerals (aa.com.tr). It has large deposits
of boron, marble, trona, feldspar, barite, gypsum,
and chromium. Valuable metals and minerals include
gold, silver, nickel, aluminium, iron, copper, lead, zinc
and antimony.
The Government claims that Türkiye has 73% of
global boron reserves, has 20.4bn tons of lignite, 40%
of global natural stone reserves, and produced 31 tons
of gold in 2022.
In April 2024, the Union of Chambers and Commodity
Exchanges of Türkiye Mining Council stated that the
sector has provided direct employment for an average
of 136,000 people in the preceding 15 years.
Tourism
The travel and tourism sector is huge too; the country
sees millions of tourist arrivals – around 57m in 2023
according to Statista.
The World Travel & Tourism Council wrote in June
2024 that the sector contributes 12% of GDP and
supports 3.2m jobs. It added that the sector is forecast
to continue breaking records in 2024, with GDP
contribution set to reach almost 12.5% of the country’s
economy… The outlook for the next 10 years forecasts
a decade of growth.
This is backed up by comment from the Daily Sabah
which wrote that foreign arrivals are expected to
reach 60m in 2024 before hitting 90m in 2028… for
income, [the Government] said they see it rising to
$60bn [in 2024] and $100bn five years from now.
That compares well to Statista’s data which reckons
that the sector was worth nearly $56bn in 2023 and has
recovered well post-pandemic. Russians are one of the
largest groups of foreign visitors to Türkiye followed
by Germans and Britons.
Summary
From what has been written it should be patently
clear that Türkiye ought to be top of many a board’s
list of potential export markets. Sitting at the
crossroads of Europe, Asia and Middle East, it’s the
perfect springboard into other territories. But just
as no organisation should commit itself without
understanding what it’s getting into, so exporters
should be aware of the instability of the economy in
terms of, for example growth and inflation.
Author: Adam Bernstein is a freelance finance writer
for Credit Magazine magazine.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 36
As voted for at the 2025 CICM British Credit Awards
DEBT
FLOOD
WARNING
Is there a debt tsunami coming?
BY GARY BROWN MCICM
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 38
CREDIT MANAGEMENT
THIS LOOMING
REFINANCING WAVE COULD
TRIGGER RECESSIONARY
PRESSURES AND HEIGHTEN
CREDIT-DEFAULT RISKS,
MAKING CREDIT RATINGS
AND ACCESS TO LIQUIDITY
CRITICAL FOR BUSINESSES
OF ALL SIZES.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 39 continues on next page >
DEBT
Global Liquidity
Much of this debt is underpinned by global liquidity.
Refinancing such a large volume of obligations in a short
two to three-year window will demand coordinated efforts
among international lenders, policymakers, and central
banks. The potential credit risks will be global in nature,
affecting not just isolated markets but also interconnected
economies worldwide.
FIVE years on from COVID, a once-ina-generation
credit event has ushered
in an extraordinary five-to-sevenyear
business cycle, now nearing its
final stages. As with the pandemic, no
organisation – large or small – is entirely
immune. This raises the prospect of
heightened credit risk across the board as a massive wave
of pandemic-era debt nears its refinancing deadlines.
A Global Surge
The near-complete shutdown of economies worldwide in
2020 added roughly $30 trillion to global debt – an increase
the IMF has described as the largest surge since World War
II. The United States alone contributed about $7 trillion,
raising its federal obligations from $23 trillion to nearly
$30 trillion by early 2022.
Total global debt across Government, corporate, and
household sectors stood at a record $307 trillion as of mid-
2023, according to the Institute of International Finance
(IIF). Many analysts estimate that by 2025, global debt
could climb to $320–$340 trillion, driven by ongoing
Government deficits, robust corporate borrowing, and
household credit demand – even in the face of rising
interest rates.
As the current business cycle winds down, a significant
portion of this debt – often carrying loan maturities of
around 65 months (average) – will come up for refinancing
between mid-2025 and mid-2027. This looming refinancing
wave could trigger recessionary pressures and heighten
credit-default risks, making credit ratings and access to
liquidity critical for businesses of all sizes.
The signs, for those who choose not to ignore them, are
already there. One early indicator of credit stress is the
gradual lengthening of trade debt payment cycles and
abuse of extended payment terms. As finances become
more strained, some organisations delay settling invoices
or push for longer terms to manage cashflow, often
shifting the burden onto suppliers and creditors. CFOs,
credit managers, and stakeholders will need to be more
vigilant than ever for this behaviour, as it can herald wider
liquidity challenges within supply chains and the broader
market.
So who will feel the strain?
While many homeowners with 30-year mortgages at
2-3% interest may be relatively shielded, those reliant on
higher-interest financing (e.g., auto loans, credit cards)
face tougher terms as rates climb. Small businesses will
also be affected. SMEs with tighter cashflows and fewer
financing channels are especially vulnerable to rising costs
and stricter lending requirements. Even smaller debt loads
can create outsized stress if revenue streams weaken and
refinancing options narrow.
But the challenge of refinancing is not something that only
affects the smaller enterprises. Much larger corporations
may also feel the pressure. Whereas those with the strongest
balance sheets and easier access to corporate bond markets
may be cushioned from the full effects, larger firms aren’t
entirely insulated; supply-chain fragility and customer
defaults can pose indirect risks.
Government Debt
The challenge is not restricted to the business world.
Governments – having issued substantial short-term debt
to cover pandemic spending – could be among the first
to face elevated refinancing costs. A notable example is
the Trump administration’s evolving fiscal strategy under
Treasury Secretary Scott Bessent, who initially unveiled a
“3 3 3 plan” in the summer of 2024.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 40
CREDIT MANAGEMENT
Credit Risk Timings to Watch
• Mid-2025: Liquidity begins to tighten as governments
and corporations start rolling over shorter-dated debt
– five years on from the initial wave of pandemic-era
financing.
• Early 2026: If the 10-year U.S. Treasury yield climbs to
5% - 6%, it would signal heightened market demand
for refinancing and higher premiums, confirming tighter
lending conditions.
• Mid-2026: The refinancing wave likely peaks, with a
concentrated volume of loans reaching maturity.
• 2026–2027: In a worst-case scenario, excessive
refinancing demands and stringent credit requirements
could lead to widespread defaults, potentially eroding
robust labour markets and undermining GDP growth.
Stress indicators – such as rising corporate delinquencies
or lengthening payment terms – could surface in the
latter half of 2026.
The plan aimed to cut the federal budget deficit to 3% of
GDP by 2028 (the last year of President Trump’s second
term), boost GDP growth to 3% through deregulation and
pro-growth measures, and increase US energy production
by an additional three million barrels of oil per day.
However, as of early February, Bessent signalled a shift
toward keeping Treasury yields low via fiscal policy
– moving away from prior calls for Federal Reserve
benchmark rate cuts. The administration now views the
10-year Treasury yield as the critical lever for managing
borrowing costs, foreshadowing more direct interventions
in Government debt markets.
Better prepared
As with any global crisis, no organisation is fully shielded
from the aftershocks of a worldwide credit squeeze.
Preparation, cost optimisation, and forward planning can
make the difference between weathering the storm and
facing severe financial strain.
Best practices would include mapping out debt maturities,
identifying and anticipating refinancing obligations
well before they come due, thereby avoiding lastminute
scrambles, when credit conditions may be less
favourable. They would also include strengthening credit
risk frameworks by implementing robust policies and
analytical tools to gauge counterparty exposure, and stresstesting
multiple scenarios and interest-rate environments
to pinpoint vulnerabilities.
Early, honest dialogue helps ensure you’re near the front
of the queue if credit tightens, while proactive discussions
often yield better terms and more flexible covenants. On
that basis, maintaining transparent lender communications
is key, as is the need to optimise all budgets available
to you. In a tightening credit environment, companies
must do more with less, and leveraging automation and
AI technologies – like Debt Register – enables firms to
stretch existing budgets further, streamlining invoice
chasing, prioritising collections, and boosting cashflow
predictability.
Leveraging AI and other digital tools helps deliver datadriven
insights that in turn help to illuminate hidden risks
and streamline decision-making, maximising the impact
of every pound/euro/dollar spent. Automated analytics
can also detect warning signs – like payment delays – well
in advance of manual processes.
Getting the basics right is key. Keep a close eye on average
days sales outstanding (DSO) and invoice payment trends
and act quickly on any signs of extended payment terms,
which can be an early signal of liquidity strain for your
customers – or for you.
Conclusion
A confluence of high debt levels, rising interest rates, and
a compressed refinancing window points to a challenging
phase for both public and private sectors. As with any
global crisis, no business – large or small can be fully
shielded from the fallout.
The best defence lies in proactive planning and strategic
action – whether through robust credit frameworks,
AI-driven analytics, or platforms that ensure your
organisation’s debts and claims are front and centre. By
optimising existing budgets and being vigilant about
payment delays, organisations can move from merely
surviving the next financial storm to emerging from it in a
position of strength.
Author: Gary Brown MCICM is Founder of Debt Register.
Key Takeaways for CFOs
and Credit Professionals
1.Refinancing Readiness
• Anticipate the crunch between mid-2025 and mid-
2027; secure options early.
2. Build Financial Resilience
• Fortify balance sheets and maintain liquidity buffers.
It’s better to have a plan and not need it than to need
one and not have it.
3. Monitor Monetary, Fiscal, and Payment Trends
• Keep a close eye on central bank policies, Treasury
yields, fiscal changes, and emerging signs of delayed
payments that could reshape credit markets.
4. Adopt Cost-Efficient Strategies
• Use AI and digital tools to get more out of current
budgets, effectively doubling results without
doubling costs.
5. Practice Ongoing Scenario Planning
• Continuously update forecasts and run scenario
analyses, staying agile as conditions evolve.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 41
CAREERS
EDUCATION OR
EXPERIENCE?
The three factors that really matter
BY NATASCHA WHITEHEAD FCICM
RESILIENCE IS A CRUCIAL SKILL
FOR THRIVING ACROSS THE CREDIT
LANDSCAPE, AND ARGUABLY THIS IS A
SKILL MORE LIKELY TO BE DEVELOPED
OUTSIDE OF EDUCATION
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 42
CREDIT MANAGEMENT
THE debate between obtaining a
degree versus on-the-job experience
is one that continues to crop up
across the world of work, and
the credit sector is no exception.
Deciding on the most valuable way
to lay the foundations for a fulfilling
and successful career in credit is by no means black and
white as every individual has different learning styles and
preferences and will follow their own unique career path.
It goes without saying that having a degree won’t harm your
chances of a fulfilling and successful career in credit, and
it can certainly support your professional journey, but the
key thing to note is that a background in higher education
is not essential. Speaking from my own experience, the
majority of people I meet don’t initially set out to work
in credit and instead they stumble across the sector, quite
by accident, and then absolutely love it! In other words,
aspiring credit professionals shouldn’t be disheartened
or discouraged if they haven’t been to university and
employers alike ought to look at the bigger picture when
hiring rather than having strict degree requirements.
According to our research, attitudes towards the necessity
of a degree amongst finance employers are relatively split,
with just over half (53%) who say an applicant’s academic
background is important compared to 47% who believe
it is not make or break that a job applicant has a degree.
Although degrees and qualifications are impressive, it’s
the other key ingredients individuals develop along the
way that will future proof their career.
Let’s explore the three factors I believe are crucial for
credit professionals to flourish.
1. Attitude
Arguably everything comes down to a person’s attitude
– with a positive attitude, an individual is more likely to
achieve their goals, be more productive, build great working
relationships, secure vast opportunities, contribute to
a healthy working environment, overcome challenges,
minimise stress and the list goes on. A professional’s
attitude impacts how they express themselves, what they
are like to work with, how they react in different scenarios
and how treat they those around them. Ultimately, all this
comes from within, regardless of whether someone has a
degree or on the job experience or both.
Having an enthusiasm to learn, grow and broaden your
horizon is an essential element of a constructive attitude;
as our research reiterates, three quarters (75%) of finance
employers believe a person’s willingness to learn is more
important than their existing skills. Especially with the
continually evolving nature of credit, professionals who
are adaptable and open to constantly improve themselves
and to venture outside of their comfort zone will stand in
good stead to go far, degree or no degree.
2. Skills
Developing a strong skillset, including both soft and
technical skills, is paramount for any credit professional.
Many soft skills needed for being successful in credit,
such as communication and the confidence to have
difficult conversations with people, are developed outside
of further education, including in customer service
jobs, retail roles and through apprenticeship schemes.
Something like time management can be enhanced during
university level education, in order to plan ahead, manage
a heavy workload and various modules and to meet
deadlines, but this is also a skill that can come with onthe-job
training and experience. Resilience is a crucial skill
for thriving across the credit landscape, and arguably this
is a skill more likely to be developed outside of education,
in scenarios such as competitive sporting environments or
dealing with challenges at home and in personal life.
The opportunity to hone our skills is all around us, and
depends largely on the experiences you go through, rather
than whether you have a degree or a certain amount of
time at a particular organisation.
3. Credibility
The importance of being both trustworthy and
knowledgeable cannot be overstated and there are several
ways to develop a level of credibility. An undergraduate
degree in areas such as mathematics, finance, accounting,
business and economics can help give you a host of
knowledge, skills and importantly credibility, but so can
being formally recognised through reputable training
programmes as well as taking part in work experience
and racking up positive references. Notably, people often
move internally into a credit role if they demonstrate the
required traits to be good at it, and then study CICM to
develop and cement their practical experience with an
industry recognised qualification. Credibility is not only
portrayed through the achievements on a person’s CV,
but more importantly in the way they approach their
day-to-day role, responsibilities and interactions in the
workplace.
At the end of the day, the criteria for being successful in
credit is complex and the focus should be on fostering
specific attributes rather than ticking an oversimplistic
degree or job experience box.
Author: Natascha Whitehead FCICM is Senior Business
Director at Hays specialising in credit management.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 43
HR MATTERS
AGE OF
PROHIBITION
Selling union lists and the practicalities of re-engaging
wayward staff.
BY GARETH EDWARDS
UNDER the Blacklist Regulations
it is unlawful to compile,
use or sell a list of people who
take part in trade union activities.
This known as a ‘prohibited
list’.
In Morais and Others v Ryanair DAC and Another, the
Court of Appeal considered whether workers who
take part in official strikes are protected from being
unfairly treated by their employer. The case involved a
group of pilots who participated in a strike organised
by their union, the British Airline Pilots' Association.
After the strike, Ryanair withdrew certain travel
benefits from the pilots, claiming they were not
entitled to these benefits due to their participation in
the strike.
The pilots argued that the withdrawal of their
travel benefits was a detriment resulting from their
participation in the strike and that by singling out
those who had taken part in strike action Ryanair had
created a 'prohibited list'.
At its appeal stages the case focused on whether
workers who take part in such strikes have legal
protection against actions like being blacklisted or
losing benefits.
The Court of Appeal ruled that workers are indeed
protected from such treatment under the Regulations
and this protection applies regardless of whether the
union followed all the formal procedures typically
required for a strike.
Ryanair argued that the pilots should not be protected
because the union’s strike action did not meet certain
procedural requirements, such as notifying the
company in advance.
The court rejected Ryanair's argument, ruling that
workers who participate in official union action,
like strikes, are protected from detriment under
the Regulations regardless of whether the union has
complied with all legal formalities.
The court made it clear that this protection is not
dependent on whether the strike action is legally
immune from claims against the union but rather
focuses on the fact that the workers were engaging in a
recognised union activity.
RYANAIR
ARGUED THAT
THE PILOTS
SHOULD NOT
BE PROTECTED
BECAUSE THE
UNION’S STRIKE
ACTION DID NOT
MEET CERTAIN
PROCEDURAL
REQUIREMENTS
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 44
CREDIT MANAGEMENT
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 45 continues on next page >
HR MATTERS
RE-ENGAGEMENT
FOLLOWING
UNFAIR DISMISSAL?
THE Employment Appeal Tribunal
(EAT) recently clarified the limits
of ordering re-engagement in
cases of unfair dismissal, focusing
on the practicalities of restoring
employment relationships and the
scope of tribunal powers.
When an Employment Tribunal (ET) upholds a complaint
of unfair dismissal, it can order remedies beyond financial
compensation. These include reinstatement, which
restores the employee to their previous role as though they
were never dismissed, or re-engagement, which places the
employee in a comparable role with the employer.
Reinstatement and re-engagement orders are relatively
rare, as tribunals must consider several factors before
granting such remedies, including the employee’s express
wish to return; whether re-engagement is practicable
for the employer; if the employee contributed to their
dismissal, whether re-engagement would be just; and
the practicability of re-engagement which hinges on
whether trust and confidence between the parties can
be restored.
In The British Council v Sellers, Mr Sellers, a longserving
employee, was dismissed for gross
misconduct following allegations of sexual
misconduct at a social event. The ET
found that the dismissal was unfair due
to a flawed investigation, which failed to
properly evaluate the evidence. It held
that the decision-maker’s belief in Sellers’
misconduct was unreasonably derived
from this flawed process.
way.
Despite this, the ET concluded that it was required to
determine whether Sellers had caused or contributed
to his dismissal. It made its own findings on the alleged
misconduct, an issue that had not been raised by the
employer and ordered re-engagement.
The EAT overturned the re-engagement order, finding
that the ET had made significant errors. It held that
tribunals are not required to assess whether an employee
contributed to their dismissal unless this is raised as a live
issue by the parties. By addressing this point unnecessarily,
the ET exceeded its remit and made findings on Sellers’
alleged conduct that were not part of the dispute.
The EAT also found that the ET had failed to
properly assess the practicability of reengagement.
Instead of focusing on whether
the British Council’s belief in Sellers’
misconduct was genuine and rationally
held, the ET scrutinised the quality of the
independent investigation. The EAT clarified
that practicability must be assessed from
the employer’s perspective. In this case, the
council’s belief that trust and confidence had
been irreparably damaged was both genuine
and rational, making re-engagement
impractical.
Author: Gareth Edwards is a partner
in the employment
team at VWV.
Following the unfair dismissal finding,
the British Council commissioned
an independent investigation which
upheld the original findings of gross
misconduct. At the remedy stage,
Sellers sought re-engagement. The
council opposed re-engagement,
arguing that it was impracticable
due to a genuine and rational loss of
trust and confidence, operational
restructuring, and disputes over Sellers’
continued residence in Council-provided
accommodation and failure to return artwork.
The council explicitly chose not to argue that
Sellers had contributed to his dismissal in any
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 46
BRANCH NEWS
UK ECONOMIC
OUTLOOK AND AGM
AGM Report: Sheffield and District Branch
BY PAULA UTTLEY FCICM
WHAT an outstanding
branch event – a fantastic
speaker in a grand
historic building, need I
say more? Well, I’m going
to have to, so please dear
reader, read on...
Sheffield & District Branch held this year’s AGM on 12
February in the Reception Room of the Grade II Listed
Cutlers Hall in Sheffield. Built in 1832 by the Company
of Cutlers of Hallamshire, on the site of the original hall
from 1638, Cutlers Hall is one of the finest livery halls on
the North of England. CICM members and guests ascended
the grand staircase and admired the stunning cutlery and
silverwork displays en route to the registration desk to sign
in before networking with other credit professionals over
refreshments and relaxing after a busy day.
Branch Chair, Jamie Thornton MCICM, opened the
meeting and welcomed everyone before handing over to the
meeting’s guest speaker, Paul Mount of Bank of England.
Paul introduced himself explaining that he joined the Bank
of England in 2019 as Deputy Agent for Yorkshire and the
Humber and that he represents the Bank in our region
and engages with businesses and public sector leaders to
understand the environment they face, and to explain the
policy stance and work of the Bank. With the assistance
of Jamie Thornton (‘next slide please Jamie’), Paul took us
through his presentation on the economic outlook. He first
clarified that the Bank’s mission is to promote the good
of the people of the UK by maintaining monetary and
financial stability. Paul talked about how the interest rate is
used to influence inflation and the Bank’s process for setting
the interest rate, which it last did just a few days prior. We
looked at the graph of the bank rate and inflation from 2001
to date (with the last inflation spike resembling Mount
Everest!) and then just the CPI since 2001, both actual and
short-term projection. So, what’s next for the base rate?
Paul shared with us some notes from the latest MPC Minutes
and also some commentary on risks from that meeting,
both upside and downside. Paul finished with a look at
the potential effects of US tariffs on the UK – watch this
space!
At the end of his presentation, Paul took questions from the
floor, and it did resemble an episode of BBC’s Question Time,
just minus the long-arm microphones. Many questions were
asked of Paul covering all topics from the time lags between
a change in the base rate and banking product interest rates,
to concerns about our local steel industry. Certainly, the
most amusing question asked to Paul was done in private
by the youngest member of the audience and that was ‘why
doesn’t the bank just print more money’!
With all questions addressed, Paul handed the meeting back
to Jamie who thanked Paul for his time and presentation.
Jamie announced that we would be moving on to the formal
AGM meeting, so non-members were given time for further
networking before taking their leave.
Jamie opened the AGM and dealt with the formalities of
apologies, approval of the 2024 AGM Minutes, approval
of the 2024 Branch Financial Report, nominations and
elections of Committee members for 2025 and then a review
of the 2024 branch events. As the winner of the third CICM
Sheffield & District Branch Student Prize - Rebecca Ross
- was unable to attend on the evening, it was noted that
the presentation would take place later that week. Many
congratulations to Rebecca for coming top in her CICM
Level 3 Diploma Mandatory Unit in 2024.
Many thanks to Paul Mount of Bank of England, Andrew
Walker of Sharp Consultancy and all attending members
and guests for making the evening a great success.
Author: Paula Uttley MCICM(Grad), Vice Chair & Treasurer
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 47
Looking for
your next
career move?
Part Time Accounts Receivable/
Credit Controller
Littlehampton, £27k - £31k pro rata
This position is a 12-month fixed term contract, to cover maternity
leave. We are looking for an organised credit professional to
start asap. The ideal candidate will have a varied skillset, with
experience in managing financial matters related to sales ledger,
including invoicing, debtor management, processing customer
payments and perform bank reconciliations. Ref: 4665824
Contact Kitty Ford on 0333 010 6339
or email kitty.ford@hays.com
Billings Assistant
Manchester City Centre, £27k + excellent company benefits
Working for a Manchester City Centre Law Firm and reporting
to the Billings Manager, you will work as part of a small Billings
team and be responsible for ensuring all invoices are created
accurately within agreed timeframes. Working closely with
partners and clients alike, you will provide assistance relating
to billings & invoice queries, providing speedy resolutions to
ensure cases are processed and closed. Ref: 2109MC
Contact Joanna Taylor-Coburn on 0161 926 8605
or joanna.taylor-Coburn@hays.com
Credit Control Administrator
Glasgow, £28k
This is a varied role that will include proactively managing
customer payments, maintaining accurate financial
records, allocation of receipts on the system and resolving
disputed queries. The ideal candidate will have the ability to
communicate clearly with others in both written and verbal
formats, and strong attention to detail.
Ref: 4666082
Contact John Crossan on 0141 212 3665
or email john.crossan@hays.com
Sole Charge Credit Control/AR
Guildford, 35k
As a skilled credit and receivable professional, you will be
responsible for ensuring that debt is monitored and collected,
in line with company terms. Duties will include raising invoices,
setting up new accounts, chasing payments, resolving queries,
and all the sales ledger administration, including allocating
payments and reconciling accounts. Hybrid working available.
Ref: 4664470
Contact Natascha Whitehead on 0777 078 6433
or natascha.whitehead@hays.com
This is just a small selection of the many opportunities we have available for credit professionals. To find out
more, visit our website or contact Natascha Whitehead, Credit Management UK Lead at Hays on 07770 786433.
hays.co.uk/credit-control-jobs
Legal Aid Biller (Civil/Crime department)
Central London, £40k - £45k
This role involves managing accurate and efficient billing for a
legal team, focusing on criminal/civil legal aid. The successful
candidate will work closely with barristers to improve billing
practices and debt recovery, while providing high-level
customer service. Candidates must have knowledge of
legal aid. Ref: 4662745
Contact Max Witek on 0203 465 0020
or email max.witek@hays.com
Legal Aid Credit Controller (Civil)
Central London, £40k - £45k
This role involves managing efficient credit control for a legal
team, focusing on debt collection and resolving queries.
The successful candidate will work closely with barristers to
improve billing practices and debt recovery, while providing
high-level customer service. Candidates must have knowledge
of legal aid. Ref: 4666165
Contact Max Witek on 0203 465 0020
or email max.witek@hays.com
Discover new
opportunities today
© Copyright Hays plc 2025. All rights are reserved. CM-00780
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 49
THE MANUFACTURING MOVEMENT:
Overcoming Challenges in a Time of Change
Manufacturing is at a crossroads. While negative
headlines often dominate the conversation, there are
also green shoots of optimism emerging within the
sector. Menzies and the CICM hosted a roundtable
discussion at the Principality Stadium in Cardiff,
bringing together key individuals in the industry
to discuss the challenges and potential solutions
shaping the future of manufacturing. Three key
themes emerged during the discussions: recruitment
and retention, supply chain challenges, and the
growing threat of fraud.
One of the most pressing concerns raised in the
roundtable was recruitment and the retention
of skilled staff. There has been a shortage of
skilled workers, which has become increasingly
evident as traditional career paths in construction
and engineering have become less sought after.
Many manufacturers struggle to replace an aging
workforce, with the retirement of experienced
employees leaving a significant skills gap.
Additionally, the impact of Brexit has meant that there
has been a decline in returning European workers,
intensifying staffing challenges.
Another significant concern was the decline of
apprenticeships. Many businesses have shifted
towards in-house training rather than relying on
external apprenticeship schemes, particularly
as training facilities in Wales remain few and
far between. Some firms even find themselves
sending trainees further afield for the required
skills development. This, combined with evolving
workplace expectations, has reshaped employment
trends. Employees are continuously prioritising worklife
balance over overtime and financial incentives,
making retention more challenging. In South Wales,
a lack of clear career pathways for young people has
led to lower retention rates among the 16-24 age
group. Roundtable participants agreed that to attract
and retain talent, manufacturers must strengthen their
employer branding by fostering social engagement
initiatives, offering flexible work policies, and providing
clear career progression opportunities.
Supply chain challenges were another key area
of discussion during the roundtable. The post-
Brexit landscape has increased reliance on
European suppliers, resulting in greater instability
and uncertainty. Many businesses are also more
dependent on China, which has therefore, led to an
increase in carbon footprints and disruptions due
to major holidays and logistical delays. Attendees
emphasised the additional supply chain risks posed
by public sector contracts, which require businesses
to conduct careful due diligence to mitigate
potential issues. In response to these uncertainties,
manufacturers are reassessing their supply chain
strategies to build greater adaptability and resilience.
Fraud and cybersecurity emerged as growing threats
within the manufacturing industry, as highlighted
by many roundtable participants. Businesses
are increasingly finding themselves targets of
highly developed phishing scams and AI-driven
cyberattacks, which inevitably leads to financial
losses and operational disruptions. Even with the
rising risks, cybersecurity awareness remains low
in countless organisations, making them vulnerable
to attacks. Roundtable participants agreed that in
order to combat these threats, manufacturing firms
must apply stringent security measures, educate their
employees on potential risks, and invest in advanced
cybersecurity technologies to safeguard sensitive
information.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 50
Despite the challenges discussed, there has been
significant developments within the manufacturing
sector. Young talent is entering the workforce,
bringing fresh ideas and enthusiasm. Many
businesses have successfully adapted to Brexitrelated
disruptions, demonstrating flexibility
and resilience in their supply chain strategies.
Companies that survived the repercussions of
COVID-19 have emerged stronger, with more
streamlined operations and improved efficiencies.
Collaboration across industries has also increased,
fostering knowledge-sharing and driving innovation.
The Welsh manufacturing sector continues to
operate well in exports, specifically in high-tech
industries. Additionally, emerging investments in
environmental, social, and governance (ESG)
initiatives, as well as advancements in science
and technology, are paving the way for remarkable
transformation. These developments indicate
a promising future for manufacturing, provided
businesses continue to embrace innovation and
adaptability.
Looking ahead, the manufacturing sector must
remain proactive in addressing its challenges
while capitalising on opportunities for growth. By
embracing technological advancements, redefining
recruitment strategies, and fostering a culture of
resilience, businesses can navigate the evolving
landscape successfully. The discussions at the
CICM roundtable underscored the importance of
collaboration, forward-thinking strategies, and a
commitment to continuous improvement. With the
right approach, the manufacturing industry can
thrive in an ever-changing economic environment.
This report is based on a roundtable event for
employers and credit professionals, chaired by the
CICM and hosted by accountancy firm Menzies LLP.
Menzies LLP’s Creditor Services team offers
complimentary support and advice to credit managers
and businesses of all sizes, across industry sectors.
Where possible, the firm’s experts provide practical
solutions for improving cash management and
operational resilience. Early management is key to
improving outcomes.
For further information on our creditor services
offering, please get in touch.
Giuseppe Parla
Director at Menzies LLP
gparla@menzies.co.uk
+44 (0)33 0912 9828
Visit www.menzies.co.uk/creditorservices for more.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 51
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OUR FULLY COMPREHENSIVE & HIGHLY DETAILED
CREDIT CONTROL SALARY SURVEY
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Based on survey data from hundreds of credit control professionals across the UK.
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LONDON 020 7650 3199
1 FINSBURY SQUARE, 3 RD FLOOR, LONDON EC2A 1AE
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recruitment@portfoliocreditcontrol.com
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 52
THE PENINSULA, VICTORIA PLACE, MANCHESTER M4 4FB
EXCLUSIVE PAYMENT TRENDS
STEADYING
THE SHIP
Late payment performance looks to be back on course.
BY ROB HOWARD
THE March edition of Payment
Trends teased choppy waters ahead,
with late payments on the rise
right across the board. The latest
figures, however, suggest a calmer
outlook, and a return to the right
course, with the majority of UK and
Irish regions and sectors improving. The average Days
Beyond Terms (DBT) across UK regions and sectors
reduced by 0.7 and 1.7 days respectively. In Ireland, the
average figures dropped by 1.5 days across both regions
and sectors. Average DBT across the four provinces of
Ireland decreased by 0.1 days.
Sector spotlight
The UK sector standings are full of positives, with three
quarters (16) of the 22 sectors making reductions to DBT.
The Real Estate sector made the biggest stride forward
and moves well clear of the bottom of the standings,
with a reduction of 10.5 days taking its overall DBT
to 9.3 days. The Health and Social sector also moved
away from the lower reaches of the table, cutting 8.5
days off its tally to take overall DBT to 8.2 days. A cut
of 5.0 days means the Business from Home sector has
leapfrogged the International Bodies sector to become
the best performing UK sector with an overall DBT of
5.4 days. Of the six sectors that saw increases in late
payments, the Financial and Insurance (+7.6 days) and
Hospitality (+4.1) sectors drop into the bottom five
worst performing sectors, now with an overall DBT of
13.8 and 14.3 days respectively.
Regional spotlight
Some eight of the 11 regions across the UK made
improvements to late payment performance, although
the vast majority of these were steady rather than
spectacular. The South West of England made the biggest
improvement (-2.9 days), meanwhile a reduction of 2.7
days for the South East take it to the summit of the UK
standings with an overall DBT of 9.9 days. Yorkshire
and Humberside is on the up too (-1.5 days), now the
second-best performing UK region with an overall DBT
of 10.5 days.
Performance across Irish counties is more of a split,
but still with the positives outweighing the negative,
with 16 of the 26 counties cutting their DBT. Of the 10
counties going backwards, Donegal (+12.8 days), Laois
(+10.9 days) and Longford (+7.9 days) took the biggest
hits. Focusing on the positives, a number of counties
– Tipperary (-8.8 days), Wexford (-8.6 days), Sligo
(-8.6 days) and Carlow (-7.4 days) took positive steps
forward. Meanwhile, a reduction of 7.5 days means that
county Leitrim is now the best performing Irish
county with an overall DBT of zero days.
Three of the four Irish provinces were moving
in the right direction, with Ulster (+7.3 days)
the only exception. Munster takes over as
the best performing province, with a
reduction of 3.4 days taking its overall
DBT to 7.3 days.
The outlook across Irish sectors is similarly positive,
with 14 of the 20 sectors making improvements,
three seeing no change and only three sectors seeing
increases to DBT. The Transportation and Storage
sector made the biggest improvement, reducing its
DBT by 10.0 days to take its overall tally to 7.0 days.
Elsewhere, the Manufacturing (-5.7 days), Education
(-4.5 days) and Construction (-4.3 days) sectors all
made gains. Meanwhile, a cut of 3.4 days for the Mining
and Quarrying sector means it joins the International
Bodies sector at the top of the standings with an overall
DBT of zero days. The Irish Real Estate sector, however,
is on the slide, with an increase of 9.1 days taking its
overall DBT to 17.1 days.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 53
*
STATISTICS
Data supplied by the Creditsafe Group
Top Five Prompter Payers
Region (UK) Feb 25 Changes from Jan 25
South East 9.9 -2.7
Yorkshire and Humberside 10.5 -1.5
London 10.7 0.2
East Midlands 10.8 -1
Scotland 10.8 0.8
Bottom Five Poorest Payers
Region (UK) Feb 25 Changes from Jan 25
Northern Ireland 14.6 -0.2
East Anglia 12.7 -1
North West 12.2 -0.6
West Midlands 11.8 2.2
South West 11.7 -2.9
Getting worse
Financial and Insurance 7.6
Hospitality 4.1
Professional and Scientific 3.7
Other Service 3.6
International Bodies 2
Business Admin & Support 0.6
Getting better
Real Estate -10.5
Top Five Prompter Payers
Sector (UK) Feb 25 Changes from Jan 25
Business from Home 5.4 -5
International Bodies 5.8 2
Agriculture, Forestry and Fishing 6.2 -4.6
Public Administration 6.8 -5.4
Entertainment 7.4 -1.5
Bottom Five Poorest Payers
Sector (UK) Feb 25 Changes from Jan 25
Hospitality 14.3 4.1
Financial and Insurance 13.8 7.6
Energy Supply 12.1 -1.9
Business Admin & Support 12.0 0.6
Manufacturing 12.0 -6.6
Health & Social -8.5
Dormant -7.2
Manufacturing -6.6
Public Administration -5.4
Business from Home -5
Agriculture, Forestry and Fishing -4.6
IT and Comms -2.3
Energy Supply -1.9
Mining and Quarrying -1.8
Wholesale and retail trade; repair of
motor vehicles and motorcycles -1.7
Entertainment -1.5
Education -0.8
SCOTLAND
0.8 DBT
Water & Waste -0.5
Transportation and Storage -0.2
NORTHERN
IRELAND
-0.2 DBT
SOUTH
WEST
-2.9 DBT
WALES
-1.1 DBT
NORTH
WEST
-0.6 DBT
WEST
MIDLANDS
-1.0 DBT
YORKSHIRE &
HUMBERSIDE
-1.5 DBT
EAST
MIDLANDS
-1.0 DBT
LONDON
0.2 DBT
SOUTH
EAST
-2.7 DBT
EAST
ANGLIA
-1.0 DBT
Construction -0.2
Region
Getting Better – Getting Worse
-2.9
-2.7
-1.5
-1.1
-1.0
-1.0
-0.6
-0.2
2.2
0.8
0.2
South West
South East
Yorkshire and Humberside
Wales
East Anglia
East Midlands
North West
Northern Ireland
West Midlands
Scotland
London
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 54
EXCLUSIVE PAYMENT TRENDS
Getting worse
CONNAUGHT
-2.6 DBT
SLIGO
-8.6 DBT
LEITRIM
-7.5 DBT
MONAGHAN
2.4 DBT
Real Estate 9.1
IT and Comms 2.9
Professional and Scientific 1.4
LIMERICK
-1.8 DBT
LAOIS
10.9 DBT
LOUTH
1.4 DBT
MUNSTER
-3.4 DBT
CLARE
-5.3 DBT
ROSCOMMON
0.1 DBT
WATERFORD
1.7 DBT
WICKLOW
xx DBT
Getting better
Transportation and Storage -10
Top Five Prompter Payers – Ireland
Region Feb 25 Changes from Jan 25
LEITRIM 0.0 -7.5
SLIGO 3.5 -8.6
LIMERICK 3.6 -1.8
CLARE 4.9 -5.3
TIPPERARY 5.6 -8.8
Bottom Five Poorest Payers – Ireland
Region Feb 25 Changes from Jan 25
WATERFORD 22.5 1.7
ROSCOMMON 22.1 0.1
LAOIS 21.5 10.9
MONAGHAN 18.4 2.4
LOUTH 17.4 1.4
Top Four Prompter Payers – Irish Provinces
Region Feb 25 Changes from Jan 25
MUNSTER 7.3 -3.4
LEINSTER 10.5 -1.9
CONNACHT 12.4 -2.6
ULSTER 16.5 7.3
Manufacturing -5.7
Education -4.5
Construction -4.3
Mining and Quarrying -3.4
Business Admin & Support -3.3
Agriculture, Forestry and Fishing -3.2
Entertainment -1.6
Public Administration -1.6
Wholesale and retail trade; repair of
motor vehicles and motorcycles -1.3
Health & Social -1.2
Other Service -1
Financial and Insurance -1
Energy Supply -1
Top Five Prompter Payers – Ireland
Sector Feb 25 Changes from Jan 25
International Bodies 0.0 0
Mining and Quarrying 0.0 -3.4
Entertainment 3.4 -1.6
Other Service 5.7 -1
Financial and Insurance 6.5 -1
Bottom Five Poorest Payers – Ireland
Sector Feb 25 Changes from Jan 25
Water & Waste 27.0 0
Professional and Scientific 18.1 1.4
Real Estate 17.1 9.1
IT and Comms 16.8 2.9
Wholesale and retail trade; repair of
motor vehicles and motorcycles 11.5 -1.3
Nothing changed
Hospitality 0
International Bodies 0
Water & Waste 0
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 55
*
International Trade
Monthly round-up of the latest stories
in global trade by Andrea Kirkby.
'GLOBAL GROWTH TEAM'
TO further the UK’s export prospects,
the Government, at the end of January
appointed a new ‘global growth team’ of
UK Trade Envoys ‘to drive UK exports and
investment’ as the Government pulls every
lever available to drive economic growth
under its Plan for Change.
Judging from the list of the 32
parliamentarians, they’ve been drawn
from across the political spectrum, with
each having been assigned target markets
around the globe and have been told to
identify trade and investment opportunities
for businesses while ‘championing the UK
as a destination of choice for investment in
those markets’.
The envoys have reportedly been
appointed on their ability, relevant skills
and experience which can be based on
their respective markets or UK sector
knowledge, including previous Governmentto-Government
experience, as well as their
commitment to the UK’s growth mission.
Looking at the appointments made
you’ve got to wonder how participants felt
when some had been given Australia or
Switzerland, but others had been handed
locations that appear less glamorous.
More importantly, will they deliver?
UK digital trade deal with the US?
ACCORDING to Business Matters, the UK
Government is seeking a deal with the US
over digital trade – all at a time of rising
global trade tensions.
Apparently, UK Government insiders think
that the prime minister has already raised
trade issues with President Trump, who in
turn has hinted a deal can be ‘worked out’
while claiming he and the prime minister are
‘getting along very well’.
Similarly, some in the US think that an
agreement of sorts could be achieved within
months, particularly if negotiations focus
on technology, digital trade and services –
the areas seen as most promising for UK
exporters.
British exports to America hit £182.6bn
in the year to November 2024, with services
accounting for 69%. It’s thought that the
digital trade agreement the UK signed with
Singapore in 2022 could act as a possible
blueprint – it streamlined regulations for
professional and financial services, law
firms, banks and tech companies.
There are, however, two sticking points:
the UK’s digital services tax. It yields
nearly £700m in tax by targeting revenue
generated by the likes of Google and Meta.
It’s possible that it may be reviewed if a
deal becomes possible; and the UK having
to choose between the US and the EU if a
trade war fully begins.
The UK is the world’s second-largest
services exporter, and since leaving the
EU, its services exports have thrived while
goods trade has lagged behind comparable
nations.
RESIGNATION OVER
LABOUR’S ‘ANTI-
BUSINESS POLICIES’
JUST as the Government created
new export roles, so another became
vacant as Mark Stewart, Chief Executive
of Gloucester-based Stewart Golf,
resigned from his role as an ‘export
champion’, which The Times said was
due to frustration with what he calls
Labour’s ‘anti-business policies’ under
Sir Keir Starmer and Rachel Reeves.
The company manufactures electric
golf buggies and exports half of its £7m
turnover to the US.
His departure came after returning
from a trip to the US where he says that
the contrast in attitudes to business
could not be starker. “I can’t be part
of this. Every turn, there’s something
that makes life more difficult for people
trying to run small businesses like
mine. I don’t feel we’re being supported
or encouraged even to try and be
better.”
He pointed specifically to Labour’s
rhetoric as undermining British
optimism, referencing the shadow
chancellor’s comments about aspiring
to ‘American-style optimism’ during a
trip on China’s bullet train. “Between
you and the boss [Starmer], all you’ve
done is talk down the UK,” Stewart said.
Stewart also expressed dismay
at Government plans for stricter
employment rights and what he sees
as punitive taxes on business assets
passed between family members,
echoing widespread disquiet among
SMEs.
The entrepreneur was one of about
400 ‘export champions’ appointed by
the Department for Business and Trade.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 56
Go to India for export growth
MONEYWEEK has highlighted that
India is on the cusp of greatness and so
should be target for any exporter looking
to grow.
However, India’s stockmarket has
slowed with concerns about the country’s
economy. This is a problem considering
that between 2020 and 2023, it delivered
a total gain of 90%.
That said, the country is one to watch
since its economy is on course to become
the world’s third largest, possibly as soon
as 2027. Then there’s the rising number
of working-age Indians. On top of that are
the middle classes that have been growing
at an average rate of 6% a year over the
past 30 years. Higher disposable incomes
clearly help spending.
Some think that India is where China
was in the 1990s and the 2000s; it’s
manufacturing could seriously take off if
the Indian Government’s target of reaching
$1tn-worth of goods exports by 2030 is
met.
Further, there’s infrastructure spending
– India has built 75 new airports in the past
five years alone and set up more than 20
metro rail projects. It now plans to invest a
further $1.4tn over the next five years and
will invest billions more in the country’s
renewable energy capacity.
So, what does this tell us?
Widening bespoke export support
RESEARCH from the FSB, Ready to
Dispatch, has found that over a third of
UK non-exporting SMEs would consider
selling to overseas markets in future, with
the smallest businesses showing greater
interest in international trade.
The body thinks that ‘boosting SME
exports must be a central part of the
Government’s new growth plan’.
The report found that 35% of nonexporting
small firms would consider
doing so in future. Some 38% of nonexporting
microbusinesses (with
under 10 employees) said they would
consider exporting, compared to 20% of
businesses with 10-49 employees.
The most beneficial tool to help small
exporters explore new markets is general
information on how to start exporting
(41%), followed by target market
information (37%) and financial support
for specific activities such as tradeshows,
translation (34%).
Bespoke Government export
support allows free access to UK-based
International Trade Advisors and in-market
trade advisors to help businesses develop
their own export strategy.
The current turnover threshold of such
services is set at £500,000. However,
61% of small employers and 91% of sole
traders had a turnover of below £500,000
and so have no access.
HIGH LOW TREND
GBP/EUR 1.21283 1.18357 DOWN
GBP/USD 1.30042 1.25624 UP
GBP/CHF 1.15009 1.12967 UP
GBP/AUD 2.06227 1.97601 UP
GBP/CAD 1.87673 1.78483 UP
GBP/JPY 194.791 188.111 UP
FSB therefore suggests the Government
reduce the turnover threshold of one-toone
export support to £400,000
and develop new tailored services for
start-ups to encourage more small firms
to trade internationally or consider it from
day one.
For the latest
exchange rates visit
www.currenciesdirect.com
or call 020 7874 9400
Currency Exchange Rates
This data was taken on 18th
March and refers to the month
previousto/leading up to 17th
March2025
CREDIT MANAGEMENT
LOOK OUT FOR
GOVERNMENT EXPORT
CONFERENCES
EARLY February the Government’s
trade body, UK Export Finance (UKEF),
held what it described as its largest
ever national conference, promoting
SME growth.
At the event some 1,000 business
leaders – including directors from CBI
and British Chambers of Commerce –
came together to help UK businesses
access international opportunities. The
event, the UK Trade and Export Finance
Forum, sought to discuss ways of
reducing financial barriers to exporting.
The majority of businesses seeking
UKEF support and attending the
conference were reported to be small
and medium-sized enterprises.
While the conference has been
and gone the point is that firms
interested in export and export-related
opportunities should keep an eye on
the UKEF website at ukexportfinance.
gov.uk for more events. The site also
has links to products and services that
it offers.
REPORTING SUSPECTED
BREACHES OF TRADE
SANCTIONS
THE Government has updated its
page on trade sanctions breaches –
breaches that may lead to enforcement
action, possible criminal prosecution or
a civil monetary penalty.
The page details how to report
a suspected breach, who to report
to – the Office of Trade Sanctions
Implementation or HMRC depending
on the matter in hand, and how to
report. There’s also detail on how
information may be shared, legal
privilege, and other obligations to be
noted.
The page is on gov.uk under ‘Report
a suspected breach of trade sanctions’.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 57
Another benefit
for CICM Members
Download and view your digital
membership card via the Folio app today!
Download the app for your iOS or Android operating system
ENFORCEMENT
CONSTRUCTIVE
PROGRESS
Engaging with the enforcement sector will deliver better
outcomes for Government and regulators as they look to shape
the future of the enforcement profession.
BY ALAN J. SMITH FCICM
LAST month, the HCEOA responded to the
Enforcement Conduct Board’s consultation
on its 2025-26 Business Plan. We didn’t
agree with absolutely every detail the ECB
is proposing, but we’re supportive of the
overall direction the organisation is taking.
What’s really important, however, is the fact that the consultation
took place in the first place. The ECB has consulted on its
draft business plan every year since its formation. It does so
in a transparent, genuine and straightforward fashion. Our
experience is that (on this and its other consultations so far) the
ECB also listens to feedback and welcomes detailed observations
that will help it achieve its objectives.
This in turn, gives the signal to consultees like the Association
that it is worth investing the time and energy to respond in
detail as it is a genuine opportunity to provide guidance for
the ECB’s next steps. The same cannot always be said for every
consultation I have been involved in responding to over the years,
but things seem to be moving forward in a positive manner.
In the past two years, we’ve responded to consultations from
the Ministry of Justice, the ECB and the Civil Justice Council.
There are a number of threads that link all of them, but two
stand out.
1) A shared focus on delivering better outcomes for everyone
involved in enforcement – debtors, creditors and the
enforcement sector – is something we characterise as a ‘fair
and effective’ enforcement service.
2) The devil is in the detail – and by that, I don’t mean that
these organisations are trying to sneak changes through in
a consultation!
There is a high degree of consensus amongst lots of the
stakeholders that I speak to and engage with – including
many in the debt advice sector as well as in Government – on
common objectives, e.g.
i) Increasing settlements at the compliance stage,
ii) Ensuring compliance with National Standards,
iii) Ensuring vulnerable debtors are identified and treated
appropriately, and
iv) The need to improve the information and guidance
that debtors currently receive. (This information is mainly
communicated through the Notice of Enforcement, which is
a prescribed document that our members must use).
It’s when it comes to detailing changes and laying out the specific
proposals and wording that the challenges come in. The phrase
‘unintended consequences’ can very quickly become very relevant.
From a High Court perspective, it is inevitably those of us
involved in enforcing Writs of Control who have the most
knowledge of the nuances of the law and the current system.
That means we are well placed to identify problems with
proposed solutions and suggest alternatives that achieve the
agreed objectives without adding unnecessary extra costs – which
will ultimately have to be funded by debtors or the taxpayer
– and that are deliverable without running into operational
roadblocks or legal minefields.
Our members are happy to share this expertise – for many of
us it is decades in the making. But it makes such a difference
when you feel that you are being listened to and appreciated
by decision-makers.
At the time of writing, we are still awaiting news from the new
Government on increasing enforcement fees. These have now
been frozen for 11 years and devalued in real terms by about 25%.
In 2023, Government also consulted on a wide range of reforms
it was considering introducing across the enforcement sector.
We, along with many others, responded in detail to this range
of proposals, and it’s fair to say that the sector is waiting for the
detailed outcomes and next steps with great interest.
Nearly all of the principles and objectives behind that
consultation were ones that would attract widespread support,
but reforms have to be deliverable and have to be affordable.
With regards to the ECB, a key focus for it this year is the
development of new standards around ‘vulnerability’ and
‘ability to pay’. It’s no small task, and the ECB has promised
to consult widely.
We’re looking forward to playing our part in a constructive and
interesting discussion that can deliver better outcomes for all.
Alan J. Smith FCICM, is Chair of the High Court Enforcement
Officers Association.
Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 59
CreditWho?
CICM Directory of Services
COLLECTIONS
COLLECTIONS LEGAL
CREDIT DATA AND ANALYTICS
Controlaccount
Compass House, Waterside, Hanbury Road, Bromsgrove,
Worcestershire B60 4FD
T: 01527 386 610
E: sales@controlaccount.com
W: www.controlaccount.com
Controlaccount has been providing efficient, effective, and
ethical pre-legal debt recovery for over forty years. We help
our clients to improve internal processes and increase cash
flow, whilst protecting customer relationships and established
reputations. We have long-standing partnerships with leading,
global brand names, SMEs and not for profits. We recover
over 40,000 overdue invoices each month, domestically
and internationally, on a no collect, no fee arrangement.
Other services include credit control and dunning services,
international and domestic trace and legal recoveries. All our
clients have full transparency on any accounts placed with us
through our market leading cloud-based management portal,
ClientWeb.
Guildways
T: +44 3333 409000
E: info@guildways.com
W: www.guildways.com
Guildways is a UK & International debt collection specialist with over
25 years experience. Guildways prides itself on operating to the
highest ethical standards and professional service levels. We are
experienced in collecting B2B and B2C debts. Our service includes:
• A complete No collection, No Fee commission based service
• 10% plus VAT commission for UK debts
• Commission from 22% plus VAT for International debts
• 24/7 online access to your cases through our CaseManager portal
• Direct online account-to-account payments, to speed up
collections and minimise costs
If you are unable to locate your customer, we also offer a no trace,
no fee, trace and collect service.
For more information, visit: www.guildways.com
MIL Collections Ltd.
Palace Building, Quay Street, Truro,TR1 2HE
M: 07961578739 E: GaryL@milcollections.co.uk
W: www.milai.co.uk
From our dedicated office in Truro, Cornwall, our team of over
50 staff work tirelessly to ensure our clients expectations are not
just met but exceeded.
We offer clients an experienced, dedicated and regulated
collection service. From small sundry invoices through to
complex property cases and overseas jurisdictions we can
help our clients recover what is due to them in a fair and timely
manner.
Added to the ISO certification, MIL is a pioneer bringing AI
to the collections world with a platform dedicated to ensure
customers are treated fairly and clients work is managed
effectively.
Lovetts Solicitors
Lovetts, Bramley House, The Guildway,
Old Portsmouth Road,
Guildford, Surrey, GU3 1LR
T: 01483 347001
E: info@lovetts.co.uk
W: www.lovetts.co.uk
With more than 25yrs experience in UK & international business
debt collection and recovery, Lovetts Solicitors collects £40m+
every year on behalf of our clients. Services include:
• Letters Before Action (LBA) from £1.50 + VAT (successful in
86% of cases)
• Advice and dispute resolution
• Legal proceedings and enforcement
• 24/7 access to your cases via our in-house software solution,
CaseManager
Don’t just take our word for it, here’s some recent customer
feedback: “All our service expectations have been exceeded.
The online system is particularly useful and extremely easy to
use. Lovetts has a recognisable brand that generates successful
results.”
CREDIT DATA AND ANALYTICS
CoCredo
Missenden Abbey, Great Missenden, Bucks, HP16 0BD
T: 01494 790600
E: customerservice@cocredo.com
W: www.cocredo.co.uk
For over 20 years, CoCredo, winner of the CICM British Credit
Awards 'Technology Development Award 2025', has been
a leading Credit Report Agency in the UK, providing online
company credit checks and business credit score information
to businesses and suppliers in the UK, Ireland and globally. Our
services include competitively priced data aggregation from top
UK, Ireland, and overseas providers. Our business credit report
service provides financial data and credit scores from companies
in 240 countries/territories. Additionally, we offer CRM integration,
Dual Reports, Business Credit Monitoring, and other essential
business credit report checking services. We have consistently
been finalists or winners in numerous Small Business and
Credit Awards. Our clients love how we actively engage in their
customer journey, delivering over 90% customer retention rate.
We consistently offer value for money, excellent customer service,
and ongoing product innovation.
DataTrace UK
Compass House, Waterside, Hanbury Road, Bromsgrove,
Worcestershire B60 4FD
T: 01527 386 626
E: info@datatraceuk.com
W: www.datatraceuk.com
DataTrace is recognised as one of the leading trace agencies in
the UK. Our client portfolio includes leading debt collection and
enforcement firms, utilities companies, housing associations,
law practices and universities. Providers of volume electronic
trace services, enhanced desktop tracing, employment and
international tracing, propensity to pay reporting, address and
telephone appending, and pre-litigation reports. We can build
a bespoke workflow to meet your data needs. All our data is
validated and priced competitively.
Dun & Bradstreet
T: 0808 239 7001
E: hello@dnb.com
W: www.dnb.co.uk
At Dun & Bradstreet, we have a standardised risk approach to
help make confident, timely, and accurate lending and credit
decisions. We help businesses access up-to-date and timely
data on hundreds of millions of global businesses. And we
don’t limit how often you’re able to run checks on businesses in
your portfolio. So, you can be sure you always have the latest
information on the companies you choose to do business with
– whether micro businesses run by a single person right up to
large, international enterprises.
TOP SERVICE
MINIMISE DEBT
Top Service Ltd
Top Service Ltd, 2&3 Regents Court, Far Moor Lane
Redditch, Worcestershire. B98 0SD
T: 01527 503990
E: membership@top-service.co.uk
W: www.top-service.co.uk
MAXIMISE C ASH
The only credit information and debt recovery service provider
specifically for the UK construction industry. Our payment
experiences are the most up to date credit information available
and enable construction businesses to confidently assess credit
risk & make the best, most informed credit decisions. Coupled
with our range of effective debt recovery solutions, quite simply
our members stay one step ahead & experience less debt &
more cash.
CREDIT MANAGEMENT SOFTWARE SOFT-
Credica Ltd
Building 168, Maxell Avenue, Harwell Oxford, Oxon. OX11 0QT
T: 01235 856400E: info@credica.co.uk W: www.credica.co.uk
Our highly configurable and extremely cost effective Collections
and Query Management System has been designed with 3
goals in mind:
•To improve your cashflow • To reduce your cost to collect
• To provide meaningful analysis of your business
Evolving over 15 years and driven by the input of 1000s of
Credit Professionals across the UK and Europe, our system is
successfully providing significant and measurable benefits for
our diverse portfolio of clients.
We would love to hear from you if you feel you would benefit
from our ‘no nonsense’ and human approach to computer
software.
Corcentric
Information: Ali Hassan| 020 317 71713
ahassan@corcentric.com | corcentric.com
Social media links: https://www.linkedin.com/company/
corcentric/, https://x.com/corcentric?lang=en-GB
Membership can go to: Lee Allen lallen@corcentric.com
Jonathan BlackBurn jblackburn@corcentric.com
Ali Hassan ahassan@corcentric.com
About Corcentric: Corcentric is a leading global provider
of best-in-class procurement and finance solutions. We
offer a unique combination of technology and payment
solutions complemented by robust advisory and managed
services. Corcentric reduces stress and increases savings
for procurement and finance business leaders by forming a
strategic partnership to diagnose pain points and deliver tailormade
solutions for their unique challenges. For more than two
decades, we've been a trusted partner who delivers proven
results. To learn more, please visit www.corcentric.com.
FOR ADVERTISING INFORMATION OPTIONS
AND PRICING CONTACT
paul.heitzman@cplone.co.uk – 01727 739 196
CREDIT MANAGEMENT SOFTWARE SOFT-
CREDIT MANAGEMENT SOFTWARE SOFT-
ENFORCEMENT
ESKER
Sam Townsend Head of Marketing
Northern Europe Esker Ltd.
T: +44 (0)1332 548176 M: +44 (0)791 2772 302
W: www.esker.co.uk LinkedIn: Esker – Northern Europe
Twitter: @EskerNEurope blog.esker.co.uk
Esker’s Accounts Receivable (AR) solution removes the
all-too-common obstacles preventing today’s businesses
from collecting receivables in a timely manner. From credit
management to cash allocation, Esker automates each step of
the order-to-cash cycle. Esker’s automated AR system helps
companies modernise without replacing their core billing and
collections processes. By simply automating what should
be automated, customers get the post-sale experience they
deserve and your team gets the tools they need.
TCN
T: +44 (0) 800-088-5089
E : spencer.taylor@tcn.com
W: www.tcn.com
TCN is a leading provider of cloud-based call centre technology
for enterprises, contact centres, BPOs, and collection
agencies worldwide. Founded in 1999, TCN combines a deep
understanding of the needs of call centre users with a highly
affordable delivery model, ensuring immediate access to robust
call centre technology, such as SMS, email, predictive dialler,
IVR, call recording, and business analytics required to optimise
operations while adhering to callers’ requests.
Its “always-on” cloud-based delivery model provides customers
with immediate access to the latest version of the TCN solution,
as well as the ability to quickly and easily scale and adjust to
evolving business needs. TCN serves various Fortune 500
companies and enterprises in multiple industries, including
newspaper, collection, education, healthcare, automotive,
political, customer service, and marketing. For more information,
visit www.tcn.com or follow on Twitter @tcn.
Court Enforcement Services
Samuel Evans – Director of Business Development
T: 07759 122503
E : s.evans@courtenforcementservices.co.uk
W: www.courtenforcementservices.co.uk
Court Enforcement Services is the market leading and fastest
growing High Court Enforcement company. Since forming in
2014, we have managed over 100,000 High Court Writs and
recovered more than £187 million for our clients, all debt fairly
collected. We help lawyers and creditors across all sectors to
recover unpaid CCJ’s sooner rather than later. We achieve 39%
early engagement resulting in market-leading recovery rates.
Our multi-award-winning technology provides real-time reporting
24/7. We work in close partnership to expertly resolve matters
with a fast, fair and personable approach. We work hard to
achieve the best results and protect your reputation.
Genius Software Solutions
T: +44 (0) 141 280 0275
E: sales@geniusssl.com
W: www.geniusssl.com
Genius provides solutions designed to enhance your customer
engagement with compliance in full focus; our team have decades
of operational experience in the Debt & BPO space.
As a global outreach partner our technology drives compliance
and operational efficiency to help your business thrive.
• Streamline Collections, Payments & Asset Recovery, whether this
be in-house or within a BPO setting with our Adept platform.
• Enhance customer engagement with our cloud-based
omnichannel platform, Commpli.
We've helped businesses worldwide enhance efficiency, optimise
workflows, and respond to the dynamic needs of a changing
marketplace.
DEBT & ASSET RECOVERY SERVICE
Shakespeare Martineau
E: jayne.gardner@shma.co.uk,
W: www.shma.co.uk
T 01789 416440
Shakespeare Martineau provides expert debt and asset
recovery services across various sectors, including energy,
manufacturing and Government. Our team supports regulated
and unregulated debt, acting as an extension of internal
collections when needed. We prioritise keeping client costs low
while empathetically engaging with debtors. Our 70+ experts
offer cradle-to-grave B2B and B2C collections, transparent
fee plans, bespoke service, flexible case management, and
additional support like training, advice, litigation and mediation.
High Court Enforcement Group Limited
Client Services, Helix, 1st Floor, Edmund St, Liverpool, L3 9NY
T: 08450 999 666
E: clientservices@hcegroup.co.uk
W: hcegroup.co.uk
Why choose us?
With over £400 million recovered for our clients, our track
record is second to none. We have enforced over 320,000 writs
of control and are committed to providing you with a unique
and personalised service. Our enforcement agents cover all of
England and Wales, are trained to the highest standards and
each holds strong local knowledge of the areas they cover.
Our clients rate our service extremely highly, with a 99%
satisfaction score in our most recent annual survey.
You can rely on us, the largest independent High Court
enforcement company in the UK, with the highest number of
HCEOs and a wealth of experience across all our teams.
ENGAGEMENT
My DSO Manager
22, Chemin du Vieux Chêne,
Bâtiment D, Meylan, FRANCE
T: +33 (0)458003676
E: contact@mydsomanager.com
W: www.mydsomanager.com
My DSO Manager is an all-in-one intelligent SaaS accounts
receivable and credit management system that provides
real-time insight and scalability from SMEs to international multientity
companies. It helps AR analysts, accounting or finance
managers, and any client-facing employee, manage risk and
maximize cash collection.
It can swiftly integrate any kind of data from any ERP and
implement any customization due to its creative, competent IT
teams that are headquartered inside the firm and collaborate
closely with support employees, many of whom were formerly
credit managers at big corporations.
The feature-rich functions, automated reminders, alerts, and
numerous services connected to the solution, such as EDM/
CRMs/insurance/e-payment/BI platforms etc., along with
a reasonable pricing system, have simplified the credit-tocash
cycle by monitoring daily KPIs like DSO, aging balance,
overdues/past-dues, customer behavior, and cash forecast.
My DSO Manager's worldwide clientele are its real
ambassadors, who assist the company in expanding on an
ongoing basis.
STA International
T: 01622 600 921
E: sales@staonline.com
W: www.stainternational.com
STA International is a trusted leader in credit management,
providing expert solutions in global debt recovery, outsourced
credit control, address tracing, and legal debt recovery. For
over 30 years, we’ve helped businesses of all sizes maximise
cash flow, minimise risk, and recover outstanding debts
efficiently.
We act as extension of your credit control team, using
technology, knowledge, and an effective ethical approach
to your debt recovery. Our bespoke processes ensure that
collections are dealt with professionally and amicably, helping to
protect your reputation and relationships while achieving results
that improve your cash flow.
Our activities on individual cases and overall performance stats
can be accessed 24/7 on our market-leading client reporting
platform, Your Debts Online. At STA International, we don’t
just recover debt; we support businesses to create healthy
financial positions while fostering better long-term customer
relationships.
CFH Docmail
T: 01761 416311
E: info@cfh.com
W: www.cfh.com
With over 45 years of experience in supporting organisations in
the successful delivery of multi-channel communications, CFH
are the innovative and trusted partner for driving engagement
and achieving measurable results.
Combining proven expertise, the right accreditations and
industry driven communication solutions including Docmail the
leading hybrid mail solution, CFH have the perfect blend of
solutions to help you engage offline, online or the perfect blend
of the two.
FINANCIAL PR
Gravity Global
Floor 6/7, Gravity Global, 69 Wilson St, London, EC2A 2BB
T: +44(0)207 330 8888. E: sfeast@gravityglobal.com
W: www.gravityglobal.com
Gravity is an award winning full service PR and advertising
business that is regularly benchmarked as being one of the
best in its field. It has a particular expertise in the credit sector,
building long-term relationships with some of the industry’s
best-known brands working on often challenging briefs. As
the partner agency for the Credit Services Association (CSA)
for the past 22 years, and the Chartered Institute of Credit
Management since 2006, it understands the key issues
affecting the credit industry and what works and what doesn’t in
supporting its clients in the media and beyond.
CreditWho?
CICM Directory of Services
FOR ADVERTISING INFORMATION
OPTIONS AND PRICING CONTACT
paul.heitzman@cplone.co.uk
INSOLVENCY
PAYMENT SOLUTIONS
RECRUITMENT
Red Flag Alert Technology Group Limited
49 Peter Street, Manchester, M2 3NG
T: 0330 460 9877
E: sales@redflagalert.com
W: www.redflagalert.com
The UK’s No1 Insolvency Score is available as platform
designed to help businesses manage risk and achieve growth
using real-time data. The only independently owned UK credit
referencing agency for businesses. We have modernised the
way companies consume data, via Graph QL API and apps for
many CRM / ERP systems to power businesses decisions with
the most important data taken in real-time feeds, ensuring our
customers are always the first to know.
Red Flag Alert has a powerful portfolio management tool
enabling you to monitor all your customers and suppliers so
you and your teams can receive email alerts on data events
i.e. CCJ, Petitions, Accounts, Directors, amongst 84 alerts
produced and tailored to your business.
Red Flag Alert works towards growing and protecting
businesses using advanced machine learning and AI
technology data to provide businesses with information
to deliver best in class sales, credit risk management and
compliance.
Menzies LLP
T: +44 (0)2073 875 868 - London
T: +44 (0)2920 495 444 - Cardiff
W: Menzies LLP.co.uk/creditor-services
Our Creditor Services team can advise on the best way for you
to protect your position when one of your debtors enters, or
is approaching, insolvency proceedings. Our services include
assisting with retention of title claims, providing representation
at creditor meetings, forensic investigations, raising finance,
financial restructuring and removing the administrative burden
– this includes completing and lodging claim forms, monitoring
dividend prospects and analysing all Insolvency Reports and
correspondence.
For more information on how the Menzies LLP Creditor
Services team can assist, please contact Bethan Evans,
Licensed Insolvency Practitioner, at bevans@Menzies LLP.
co.uk or call +44 (0)2920 447 512.
Key IVR
T: +44 (0) 1302 513 000 Opt 3 E: partners@keyivr.com
W: www.keyivr.com
Key IVR are proud to have joined the Chartered Institute of
Credit Management’s Corporate partnership scheme. The
CICM is a recognised and trusted professional entity within
credit management and a perfect partner for Key IVR. We are
delighted to be providing our services to the CICM to assist
with their membership collection activities. Key IVR provides
a suite of products to assist companies across the globe with
credit management. Our service is based around giving the
end-user the means to make a payment when and how they
choose. Using automated collection methods, such as a secure
telephone payment line (IVR), web and SMS allows companies
to free up valuable staff time away from typical debt collection.
Bottomline Technologies
115 Chatham Street, Reading
Berks RG1 7JX | UK
T: 0870 081 8250 E: emea-info@bottomline.com
W: www.bottomline.com/uk
Bottomline Technologies (NASDAQ: EPAY) helps businesses
pay and get paid. Businesses and banks rely on Bottomline for
domestic and international payments, effective cash management
tools, automated workflows for payment processing and bill
review and state of the art fraud detection, behavioural analytics
and regulatory compliance. Businesses around the world depend
on Bottomline solutions to help them pay and get paid, including
some of the world’s largest systemic banks, private and publicly
traded companies and Insurers. Every day, we help our customers
by making complex business payments simple, secure and
seamless.
RECRUITMENT
Hays Credit Management
107 Cheapside, London, EC2V 6DN
T: 07834 260029
E: karen.young@hays.com
W: www.hays.co.uk/creditcontrol
Hays Credit Management is working in partnership with the
CICM and specialise in placing experts into credit control jobs
and credit management jobs. Hays understands the demands
of this challenging environment and the skills required to thrive
within it. Whatever your needs, we have temporary, permanent
and contract based opportunities to find your ideal role. Our
candidate registration process is unrivalled, including faceto-face
screening interviews and a credit control skills test
developed exclusively for Hays by the CICM. We offer CICM
members a priority service and can provide advice across a wide
spectrum of job search and recruitment issues.
PORTFOLIO
CREDIT CONTROL
Portfolio Credit Control
1 Finsbury Square, London. EC2A 1AE
T: 0207 650 3199
E: recruitment@portfoliocreditcontrol.com
W: www.portfoliocreditcontrol.com
Portfolio Credit Control, a 5* Trustpilot rated agency, solely
specialises in the recruitment of Permanent, Temporary &
Contract Credit Control, Accounts Receivable and Collections
staff including remote workers. Part of The Portfolio Group,
an award-winning Recruiter, we speak to Credit Controllers
every day and understand their skills meaning we are perfectly
placed to provide your business with talented Credit Control
professionals. Offering a highly tailored approach to recruitment,
we use a hybrid of face-to-face and remote briefings, interviews
and feedback options. We provide both candidates & clients
with a commitment to deliver that will exceed your expectations
every single time.
PAYMENT SOLUTIONS
American Express
76 Buckingham Palace Road,
London. SW1W 9TQ
T: +44 (0)1273 696933
W: www.americanexpress.com
American Express is working in partnership with the CICM
and is a globally recognised provider of payment solutions
to businesses. Specialising in providing flexible collection
capabilities to drive a number of company objectives including:
• Accelerate cashflow • Improved DSO • Reduce risk
• Offer extended terms to customers
• Provide an additional line of bank independent credit to
drive
growth • Create competitive advantage with your customers
As experts in the field of payments and with a global reach,
American Express is working with credit managers to drive
growth within businesses of all sectors. By creating an additional
lever to help support supplier/client relationships American
Express is proud to be an innovator in the business payments
space.
DCS
T: 01656 663 930
E: Jason@creditpro.co.uk
W: www.dcscreditjobs.co.uk
DCS is a specialist Credit Management Recruitment
Company with over 18 years of experience, supplying
Credit Professionals at all levels.
We supply high calibre candidates to our clients within the
FinTech, Credit, Collections, Enforcement and Legal Industry.
We also cover many different sectors listed below
Utilities Gas / Electric / Water / Collections
International Collections & Credit Insurance
DCA Collections, Legal, Enforcement & Asset Recovery
Credit Information, Credit Management Software, Data &
Analytics, Invoice Factoring and Invoice Discounting,
Insolvency, Payment Solutions, Parking, Banking.
CreditWho?
CICM Directory of Services
For advertising information
options and pricing contact
paul.heitzman@cplone.co.uk 01727 739 196
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