Credit Management magazine June 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
THE CICM MAGAZINE FOR CONSUMER AND
COMMERCIAL CREDIT PROFESSIONALS
JUNE ISSUE 2025
Red Flag
The FCA gets serious
on financial crime
CONSUMER
More needs to be
done to support
mental health.
PAGE 12
INTERVIEW
Father and son
elected to the
Advisory Council.
PAGE 24
ENFORCEMENT
Fee increases are
inappropriate and
unjustifiable.
PAGE 22
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SEAN FEAST FCICM
MANAGING EDITOR
Editor’s column
DOES CONSUMER
DUTY DESERVE
THE CREDIT?
FIGURES published a few weeks ago
by the Financial Conduct Authority
(FCA) show that complaints against
firms in the regulated consumer
finance space have fallen overall by
more than 4% (H2 2024 compared to
H1).
Banking and credit card complaints fell by 1.3%, with
decumulation and pensions down by 4.2% and home
finance complaints 10% lower at 83,936. There were also
decreases in the three most-often complained about
products: current accounts by 0.3%; motor and transport
by 8.0%; and credit cards by 2.4%.
The good news continues into the consumer collections
space. Speaking to Chris Leslie, Chief Executive of the
Credit Services Association, he welcomes the news as
well as the fact that only relatively few complaints about
the collections sector are ending up with the Financial
Ombudsman Service, and with a complaint ‘uphold’ rate
of just 24% this is significantly better than the average
for the rest of complaints against financial services firms
generally (see news special page 6).
Much smarter people than me attribute the fall to
the success of the FCA’s Consumer Duty initiative.
Sue Chapple, the CICM’s Chief Executive, says that
Consumer Duty has changed the way that creditors and
debt collectors do business. She stops short of attributing
all the success to the FCA’s actions but acknowledges
that they are taking ‘a step in the right direction’.
Many of the complaints registered against firms like
Lowell and Cabot involved in debt sale and purchase,
for example, will be around the fact that the debt has
been sold in the first place, rather than there has been
any consumer detriment, and that probably counts for
the comparatively low number of complaints that are
upheld.
Instinct tells me that Consumer Duty may all have
something to do with it, but that one swallow doesn’t
make a summer, and one six-month falls does not make a
trend. Chris agrees. He says it is still too early to tell. He
also, most interestingly, says that Consumer Duty could
equally be a source of new complaints in the years ahead
if these broader, less-definitive duties generate a broader
range of less rule-specific complaints. So let’s wait
and see.
But given the falling number of complaints that are
upheld, perhaps the FCA could be looking at the issue
from another angle. Could making it more difficult
to complain, rather than easier and openly inviting
complaints, actually make it better for those who are
vulnerable or have a genuine grievance? Or will the
vulnerable be even less inclined to complain – and
therefore increase their vulnerability – if they are greeted
with something they see as an impenetrable roadblock?
Reducing the volume of complaints would certainly be a
good thing for everyone. Every complaint received adds
a cost to the recipient, consuming time and resource
that could be better deployed. The higher the volume of
complaints, the more difficult it also becomes to discern
the ‘genuine’ cases who deserve focus from those that are
nefarious or mischievous in nature or are being made to
shift blame or responsibility.
Perhaps it’s time for a more radical rethink before
anyone starts patting themselves on the back. It’s a
tricky one. The best measure of real progress is surely
the percentage of complaints that are upheld, rather
than the volume received. A fall in complaints does not
necessarily suggest the consumer is getting a better deal.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 3
contents
JUNE 2025 issue
11 – RESTRUCTURING PLANS
What are they and what impact can they have
on creditors?
12 – MIND GAMES
How can the credit industry respond and fulfil
its responsibilities to its vulnerable customers?
16 – CUTTING IT FINE
FCA fines – are your controls up to scratch?
22 – TRANSFER FEE
A fair fee for enforcement is long overdue.
24 – INTERVIEW
Sean Feast FCICM speaks to two members
of the Advisory Council with a family
connection.
31 – ROUGH JUSTICE
The wrong increase at the wrong time.
32 – COUNTRY FOCUS
There is more to Saudi Arabia than sand
and oil.
38 – REMEDIAL ACTION
Why backing the Civil Justice Council’s
Enforcement Report matters.
40 – RAIN OR SHINE
The challenges of speculating, age, and
umbrella companies.
42 – IN REAL-LIFE
How to make industry events worth
your while.
44 – FUNDING LINES
Litigation funding: to regulate
or not to regulate?
52 – THE WALLS OF JERICHO
Is the construction industry on the brink
or are statistics misleading?
16
CUTTING IT FINE
How can the credit
industry respond to
vulnerability?
11
INSOLVENCY
What are they and what impact
can they have on creditors?
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 4
24
INTERVIEW
CICM GOVERNANCE
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 FCICM(Grad)
Natalie Bunyer FCICM / Glen Bullivant FCICM
Alan Church FCICM(Grad) / Larry Coltman FCICM
Peter Gent FCICM(Grad) / Tom Hope MCICM
Neil Jinks FCICM / Martin Kirby FCICM
Charles Mayhew FCICM / Joshua Mayhew MCICM
Hans Meijer FCICM / 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
32
COUNTRY FOCUS
Publisher
Chartered Institute of Credit Management
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Peterborough PE2 6XS
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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
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Telephone: 01727 739 196
Email: paul@centuryone.uk
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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.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 5
THE NEWS
CMNEWS
A round-up of news stories from the
world of consumer and commercial credit.
WRITTEN BY: SEAN FEAST FCICM
FCA fall in complaints down
to success of Consumer Duty
LATEST figures from
the Financial Conduct
Authority (FCA) show
that complaints in the
regulated consumer
finance space fell in
the second half of 2024,
which experts in part attribute to the success
of the FCA’s Consumer Duty initiative
which mandates that firms prioritise
customer needs in their operations.
In H2 2024, financial services firms
received 1.78m complaints, a 4.3% decrease
from H1. Since 2021, complaints have stayed
relatively constant between 1.7m and 2.0m.
All product groups saw a decrease in
their complaint numbers in H2: banking
and credit card complaints fell by 1.3%,
with decumulation and pensions down
by 4.2% and home finance complaints 10%
lower at 83,936. There were also decreases
in the three most-often complained about
products: current accounts by 0.3%; motor
and transport by 8.0%; and credit cards by
2.4%.
The percentage of complaints that were
upheld by firms remained around 57%
between H1 and H2 2024. In H2 2024 the
total amount of redress was £236m. This is
a 3.0% decrease on the H1 figure of £243m.
In terms of specifics, the most complained
about firms in the consumer credit space
were Black Horse (Lloyds Banking Group)
with just short of 261,000 complaints of
which almost half (48%) were upheld;
First Rand Bank (the largest financial
institution by market capitalisation in
Africa whose portfolio in the UK includes
Aldermore) with approximately 136,000
complaints with only 10% upheld; and
BMW Financial Services with around
142,000 complaints and only 13% upheld.
Analysis of the tables shows that there
were more than 73,000 complaints made
against Close Brothers, 50,000 against
Clydesdale Financial Services, 44,000
against RCI Financial Services, 31,000
against PayPal and 21,000 against Mercedes
Benz Financial Services.
Darren Richards, Head of Insurance,
Regulatory and Risk at independent
financial services consultancy Broadstone,
says he is pleased to see complaints falling:
“While the drop is a small one for now,
it nonetheless marks a step in the right
direction and suggests that initiatives
like Consumer Duty are starting to pay
dividends. Markets remain volatile and
consumer confidence shaky, so financial
services firms need to retain a laser focus
on ensuring they are looking after the longterm
financial interests of their customers
throughout their interactions.”
Hugh Fairclough, Partner and Head
of Financial Services at RSM UK agrees:
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 6
“The decreasing complaints seen across all
financial services products is good news and
suggests that measures to improve outcomes
for customers introduced by Consumer
Duty are having a positive impact. Many
firms have improved their customer service
practices in response, which may now
be coming through in today’s H2 2024
complaints data.”
Within the collections space specifically,
and in detail, Lowell Financial Limited
received 8,028 complaints with 26.25%
upheld; Cabot Credit Management received
6,159 complains with 18.54% upheld;
PRA Group UK Limited received 1,977
complaints with 19.41% upheld; and Wescot
Credit Services Limited received 1,823
complaints with 22.4% upheld.
Capquest Debt Recovery (Intrum Group)
had a low number of complaints (803) but
a high number were upheld (55.18%), so too
Moorcroft Debt Recovery Limited (578 and
46.06% respectively). Also on the list were
Lantern Debt Recovery (1,135 complaints
with 21.84% upheld).
Sue Chapple FCICM, Chief Executive
of the Chartered Institute of Credit
Management, believes that while there are
a number of features that will impact the
complaints, Consumer Duty has changed
the way that creditors and debt collectors
do business: “While one set of figures does
not necessarily indicate a trend, it’s certainly
a step in the right direction,” she says.
“Of the firms that are complained against
in the collections sector, for example, many
are from the world of debt purchase and
doubtless many of the complaints will be
around the fact that the debt has been sold
in the first place, rather than there has been
any consumer detriment, and that probably
counts for the low number of complaints
that are upheld.
“It’s also interesting to note,” she
continues, “that Trust Pilot and Google
ratings of collections firms have shifted
upwards significantly, and that also speaks
to an industry whose leaders – many of
whom are members of the CICM – are
taking huge strides in treating customers
fairly.”
Chris Leslie, Chief Executive of the Credit
Services Association (CSA), told Credit
Management: “It’s positive that relatively few
complaints about the collections sector are
ending up with the Financial Ombudsman
Service, and with a complaint ‘uphold’ rate
of just 24% this is significantly better than
the average 34% for the rest of complaints
against financial services firms generally.
These numbers tally broadly with our own
experience adjudicating complaints from
the public about members of the CSA and
compliance with our Code of Practice. And
the FCA’s complaints data seems to tell a
similar story.
“While the
drop is a small
one for now,
it nonetheless
marks a step
in the right
direction and
suggests that
initiatives like
Consumer Duty
are starting to
pay dividends.’’
“Perhaps there are a variety of reasons
for this,” he continues, “including the
continued professional development of the
collections sector, the general economic
climate and of course the activities of
third-party complaints management
companies who often target different
sectors at different times. While the advent
of the FCA’s Consumer Duty has helped
reinforce good practices across all parts of
the regulated financial services sector, it
is still quite early days to know if this is a
cause for lower complaints. It could equally
be a source of new complaints in the years
ahead if these broader, less-definitive duties
generate a broader range of less rule-specific
complaints. On this I think the jury is still
out.”
Other notable firms on the list include
Experian who received 11,397 complaints
with 16.97% upheld; Transunion
International UK Limited (2,285 and
21.92%); and Equifax Limited (2,117 and
37.48%).
While motor finance firms tended to
do badly, they also registered some of the
better successes. Toyota Financial Services
UK received 27,267 complaints with only
4.83% upheld; and Hyundai Capital Uk
Limited received 13,329 complaints with
only 5.48% upheld.
Commenting on the figures, a Black Horse
spokesperson told Credit Management: “We
want to provide the best possible experience
for our customers. However, if something
doesn’t go as well as it should, we work hard
to address it as quickly and sensitively as
possible and look to resolve the root cause
of any issue."
BMW declined to comment.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 7
CREDIT MANAGEMENT
Trade deal
ALLIANZ Trade in Asia Pacific has
appointed Rodrigo Jimenez as Asia
Pacific Regional CEO to succeed Paul
Flanagan who is retiring after 34-years
with the business. Rodrigo will assume
his new responsibilities in October,
subject to standard regulatory approval
requirements. Joining Allianz Trade
in Brazil as CEO in 2014, Rodrigo is
currently Regional Commercial Director
for the Northern Europe region. He
is described as a keen advocate of
digital transformation and has been
closely involved in a number of crucial
transformation projects in the Northern
Europe region.
Regional growth
CASHFLOW finance provider eCapital
Commercial Finance (eCapital) has
appointed Jason Sedgwick as Regional
Sales Manager within its South of England
team. The appointment is said to enhance
eCapital’s sales presence as the company
continues its growth trajectory in the
competitive financial services market. It
is also said to reaffirm eCapital’s strategic
focus on each region of the UK. Jason will
be aligned with the Southern sales team
based out of the Reading headquarters,
while primarily focusing his business
development activities in and around
Essex, Cambridgeshire, Hertfordshire,
East Anglia, and Peterborough.
Imaginative Render
EQUIFAX UK has formed a strategic
partnership with Render to launch
what it describes as a comprehensive
data decisioning platform for lenders
that uses Equifax credit bureau data and
categorised Open Banking insights. The
firm says that the new platform – Clear
Decision, powered by Render – will help
lenders make more informed decisions
based on customers’ individual financial
circumstances, using a combination of
Credit Reference and Open Banking
data that provides an enhanced picture
of affordability and creditworthiness. In
particular, it will help lenders tackle the
challenge of marginal credit applications.
continues on page 8 >
THE NEWS
Banks face mixed fortunes
as uncertainty grows
THE main High Street
banks have reported
mixed fortunes in the
first quarter of 2025,
with profit rises for
NatWest, Barclays
and TSB and falls for
Santander and HSBC.
NatWest reported a 36% increase in
profits in the first quarter of this year,
reaching £1.8bn, up from £1.3bn last year.
The bank's revenues rose to £4bn, boosted
by higher deposits in its retail and commercial
bank. The amount of money deposited
by customers increased by £2.1bn during
the period, while net loans increased by
£3.4bn, driven by mortgage and business
lending.
Barclays similarly reported a 19% increase
in pre-tax profits, reaching £2.72bn for
the first quarter, despite facing economic
challenges. The bank has raised its loan loss
provisions to £643m, up from £513m a year
earlier, with £74m attributed to elevated
US macroeconomic uncertainty.
Effective cost-cutting measures and a
fall in operating costs were the cause of a
surge in profits for TSB. It posted a profit
of £101.3m in the first quarter, up from
£53.4m last year. The lender experienced a
particular boost in its mortgage portfolio.
Santander, meanwhile, experienced an
8% decrease in profits compared to the
same period last year. Commenting on a
pre-tax profit of £358m for the first quarter,
Chief Executive Mike Regnier stated that
charges relating to changes to its branch
network were largely to blame. The bank
is restructuring its operations, leading to a
69% increase in provisions to £140m.
As part of this overhaul, Santander plans
to close 95 branches and reduce hours at 36
locations, putting 750 jobs at risk. The bank
has also revised its UK economic growth
forecast down to 0.8% for this year, citing
reduced consumer confidence and geopolitical
uncertainties.
HSBC’s profits also took a hit. It reported
a pre-tax profit decline of £2.4bn, totalling
£7.1bn for the first quarter of 2025, a drop
attributed to economic uncertainty and
market unpredictability. The bank’s revenue
also fell by 15% year-on-year, amounting
to £13.2bn.
HSBC increased its provisions for bad
loans and predicted lending would be
muted this year. Group Chief Executive
Georges Elhedery described the results as
‘strong,’ pointing to the bank's resilienceamid
global economic challenges.
Profit warnings signal need for resilience NEWS
UK-listed companies issued 62 profit
warnings during Q1 2025, an 11% year-onyear
fall. The proportion of listed firms
to warn in the last 12 months, however,
remains high (18%).
EY-Parthenon’s latest Profit Warnings
report found that the leading factor
behind profit warnings in Q1 was contract
and order cancellations or delays, cited in
40% of warnings – the highest percentage
recorded for this cause in 25 years of EY’s
analysis. Policy change and geopolitical
uncertainty (26%) and labour market
issues (18%) were cited as the other main
drivers for warnings during Q1.
So far in Q2, half (50%) of the profit
warnings issued by UK-listed businesses
in April cited the direct or indirect impact
of tariffs and resulting recent global trade
disruption. The average share price fall
on the day of warning also climbed, up
from 13% in Q4 2024 to 17% in Q1 2025 and
almost a fifth (19%) in April 2025.
Jo Robinson, EY-Parthenon Partner
and UK&I Turnaround and Restructuring
Strategy Leader, says the latest profit
warnings data reveals underlying
weaknesses that will be magnified by
recent tariff disruptions and the resulting
economic fallout: “Nearly one in five
listed firms issued a warning in the last
12 months and that's a level typically
associated with a period of economic
shock,” he explains.
“UK businesses have faced
unprecedented challenges in recent years
and have developed admirable levels of
resilience in response, which should serve
many well as the global economy navigates
the coming months of uncertainty.
At times like these, businesses must
focus on staying nimble by planning
for a range of different scenarios and
continuing to build operational and
financial resilience.”
The FTSE sectors with the highest
number of profit warnings in Q1 2025 were
Software and Computer Services, with 10
warnings issued, and Industrial Support
Services – which encompasses business
service providers, industrial suppliers and
recruitment companies – with nine. FTSE
Construction and Materials companies
issued five profit warnings during the first
quarter.
Claire Gambles, EY-Parthenon
Turnaround and Restructuring Strategy
Partner, believes ongoing global trade
disruption has the potential to bring
even more substantial and far-reaching
repercussions: “Demand and supply shocks
from the pandemic and geopolitical events
were significant but primarily cyclical
disruptions, whereas major changes to
international trade policy may have more
enduring effects.
“Naturally, these changes won’t happen
immediately, and companies will need
to balance immediate responses, such as
strengthening financial resilience, with
strategic shifts, whether by reassessing
supply chains and pricing models or
exploring new global partnerships, to
help respond to further uncertainty over
the coming months.”
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 8
THE NEWS
Family support brings
younger buyers to market
NEW analysis from UK Finance has
highlighted the impact of family financial
support in the first-time buyer (FTB)
market – often known as the Bank of Mum
and Dad.
In looking at assisted and unassisted
buyers in terms of deposits, age, household
income and purchase price in 2024 UK
Finance found notable differences across
these in each region of the UK.
Nationally, first-time buyers who receive
assistance are able to buy a home at an
average age of just over 30, with an average
household income of £56,000. In contrast,
those purchasing without support tend
to be older—over 32 years old—and have
a higher household income, at £65,000.
Despite this, assisted buyers are on average
purchasing higher-priced properties,
thanks to larger deposits facilitated by
family support.
This divide is seen across the UK but
the difference in deposit amounts is most
pronounced in London. In 2024, a firsttime
buyer purchasing without support
typically put down a deposit of nearly
£150,000. However, for those receiving
family assistance, the average deposit was
just under £225,000.
UK Finance also looked at the impact of
the temporary Stamp Duty holiday, which
the Government introduced during the
pandemic. This was aimed at supporting
the market during a period of economic
instability, but it appears to have had
uneven effects, helping those who could
also get help from the Bank of Mum and
Dad the most.
By reducing transaction costs, analysis
by UK Finance found a disproportionate
increase in the number of assisted-
FTBs. UK Finance also found that the
policy coincided with a notable increase
in borrowers withdrawing very sizeable
amounts of equity when remortgaging,
suggesting that some households were
drawing on their own property wealth to
help family get on the housing ladder.
James Tatch, UK Finance’s Head of
Analytics, says that while the majority
of first-time buyers are still managing
to purchase without help, the growing
reliance on family support risks deepening
inequality in the housing market: “A
balanced approach which addresses both
supply and affordability issues is essential
to ensure the door to homeownership
remains open to all,” he says.
New US trade deal greeted
with cautious optimism
THE US-UK Trade deal, secured just
as Credit Management went to press, has
received mixed reviews from industry
leaders as the details of the deal become
clearer.
Sir Keir Starmer and US President
Donald Trump hailed the trade deal
between the UK and the US as ‘historic’,
which eases some, but not all, of the tariffs
imposed by the US in April.
The deal will see tariffs on British car
exports to the US fall from 27.5% to 10%,
for the first 100,000 vehicles per year; the
25% tariffs on steel and aluminium will
be removed and the UK’s pharmaceutical
industry has been promised preferential
treatment. British beef farmers will be
allowed access to the US market and vice
NEWS
versa, with no reduction in food standards
in the UK. Jonathan Reynolds, the Business
and Trade Secretary, said the UK would
continue trying to reduce the 10% baseline
tariff, adding that the agreement did not
include any concessions on the digital
services tax, online safety laws, or the NHS.
A separate deal on technology is expected
to be agreed at a later date.
UK manufacturers currently export in
excess of 100,000 vehicles to the US but
Mike Hawes, Chief Executive of the Society
of Motor Manufacturers and Traders, still
gave a cautious welcome to the news: "The
application of these tariffs was a severe
and immediate threat to UK automotive
exporters so this deal will provide much
needed relief."
All square
SQUARE 4 Partners, a consultancy and
interim solutions provider specialising
in governance, risk, and compliance,
has appointed Roma Pearson as Senior
Advisory Director within its Consultancy
Division. Roma previously served as
Director of Consumer Finance at the
Financial Conduct Authority (FCA).
Her appointment comes at a critical
time for financial services firms as they
face increasing pressure to meet evolving
regulatory expectations, particularly in
relation to the Consumer Duty regime
and the FCA’s shift towards outcomesbased
supervision. At the FCA, Roma led
the supervision and policy development
of the consumer lending market and held
several senior positions, including Head
of Mortgages & Consumer Lending, Head
of Retail General Insurance, and Head of
Risk Advisory.
Perpetual motion
CAPGEMINI has announced the
rollout of a technology sandbox that
offers financial institutions a sound
framework to migrate from legacy, static
Know-Your-Customer (KYC) processes
and labour-intensive periodic reviews
towards perpetual KYC (pKYC) and
event-based reviews. Described by the
firm as a first of its kind, Capgemini has
collaborated with multiple technology
partners to orchestrate the integration
of this architecture. The sandbox offers
a safe and secure test environment for
firms to visualize how they can transition
to a pKYC process and demonstrate its
effectiveness to senior management and
regulators.
Approval stamp
POST Office branches will continue to
provide access to cash for another five
years following a new agreement with
banks. Neil Brocklehurst, the new Chief
Executive, stated that this partnership
will underpin access to cash for millions
of individuals and small businesses.
Customers of 30 banks and building
societies will be able to perform various
transactions at their local Post Office,
which is also enhancing postmaster
remuneration for cash handling.
Additionally, The Post Office says it
will be making a significant investment
in automating cash services to lower
operational costs.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 9
continues on next page >
THE NEWS
Solaris completes
purchase of Equivo
Legal Services
SOLARIS Law, part of the Azzurro
Group, has completed the purchase of
the Equivo Legal Services division. This is
the final part of a two-stage transaction
which sees the Equivo legal team join
Solaris Law and follows the first stage of
the transaction in 2024 to purchase the
Shoosmith’s commercial debt recovery
team and integrating it into its new
Solent office.
The purchase creates one of the largest
commercial and consumer specialist
collections and legal debt recovery
businesses in the UK with a focus on
Asset and Motor finance recoveries,
Mortgage recoveries, Unsecured lending
and commercial and business to business
debt recovery.
Solaris Law will be structured as two
law firms with the new Consumerfocused-firm,
led by Mel Chell having
both Solicitor Regulation Authority
(SRA) and Financial Conduct Authority
(FCA) permissions. The Commercial law
firm, which will be regulated by the SRA,
will continue to be led by Karen Bulgarelli,
CEO of Solaris Law. Both Karen and Mel
are lawyers and were formerly Partners of
Shoosmiths.
Work has already started on transitioning
the teams into the new business, which
the firm says will now comprise over
190 paralegals, lawyers and support
staff across offices in Southampton,
Northampton and Manchester. The case
management platform is common across
Dispute resolution
scheme faces scrutiny
THE Business Banking Resolution
Service (BBRS), established to assist small
businesses affected by banking scandals
and financed by the participating banks,
is facing ongoing criticism for its financial
management.
Critics argue that the BBRS has
functioned more as a protective measure
for banks than a support system for
victims. The BBRS in its quarterly report
(April 2025), however, claims that to date it
has secured more than £2.75m of financial
redress as a result of its intervention, and
the true figure ‘is likely to be significantly
higher’.
As of 31 March 2025, the BBRS had a
total of 1,106 case registrations and says
all parties, and further investment into
additional systems and infrastructure is
already underway.
Equivo’s Field Team and High Court
Enforcement Business will not form part
of the new business and will continue to
operate under the Equivo brand.
Mel Chell.
Karen Bulgarelli, CEO of Solaris Law.
NEWS
that in addition to the 130 customers
who have received financial award or
settlement, BBRS ‘has also resolved cases
to the satisfaction of the customer and the
bank in instances where no award has been
made’.
A spokeswoman quoted in The Times said
the service had been ‘established to address
a scale of complaints that ultimately didn't
materialise and our set-up and operating
costs reflect that, as well as the complexity
of the cases.’
They added that the service also achieved
‘non-financial outcomes’ for complainants.
The BBRS closed to new complaint
registrations in December 2024 and is set
to close by the end of 2025.
Switching off
ACCORDING to a survey for Smart
Money People by Opinium, nearly a third
(31%) of respondents would only consider
switching financial services providers if
the new company had a minimum rating
of four stars out of five. The survey
revealed that 74% of participants read
reviews before making decisions about
financial products. The research also
highlighted that 62% of reviewers shared
positive experiences, while 42% reported
stressful situations with their providers.
Building foundations
TAYLOR Wimpey has reported good
levels of customer demand leading to a
robust start to 2025, with its order book
reaching £2.34bn, nearly £300m higher
than last year. Despite this positive
outlook, the company's shares have fallen
by over 25% since last October. The firm
plans to build between 10,400 and 10,800
homes this year, but analysts expect a
return to pre-pandemic levels of over
16,000 homes.
Life’s a gas
LEEDS Building Society says it has
dramatically improved the accuracy of
its reported financed emissions within
its residential lending portfolio thanks
to a new partnership with Experian. The
improvement aligns with the transition
to a low-carbon economy and the
Government’s Net Zero ambition. As part
of that journey, UK lenders are obliged to
report Scope 3 financed emissions, which
can account for anywhere between 80%
and 95% of a business’ total footprint. By
deploying Experian datasets, the building
society has been able to access aggregated
and anonymised property level energy
data and emission factors for properties
in its portfolio. This has removed its
reliance on estimated EPC data which
was found to have overestimated its
residential mortgage emissions by more
than a third (36%).
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 10
.
INSOLVENCY
RESTRUCTURING
PLANS
What are they and what impact can they have on creditors?
BY GIUSEPPE PARLA
RESTRUCTURING Plans (RPs)
are very much in the news at the
moment, not least because they
are being used to save Thames
Water. But what is an RP
and could they be something
we may be seeing more of as a
credit manager?
The Corporate Insolvency and Governance Act
2020 introduced the new RP during the COVID-19
pandemic, with the aim of helping companies avoid
insolvency whilst ensuring creditors and stakeholders
are treated fairly.
Unlike any other ‘traditional’ insolvency procedures,
an RP provides greater flexibility in how it is
structured, allowing companies to propose bespoke
solutions that suit their financial situation. It can also
help a company remain operational, preserve jobs and
maintain relationships with customers and suppliers,
while avoiding a formal insolvency process, where
returns to key stakeholders may be impacted more
severely.
While RPs offer some benefits, however, they also
come with challenges and risks. So it’s worth knowing
how RPs are approved and their impact on creditors’
rights, so you can determine what actions to take next.
Obtaining approval
For a company to implement an RP, it must satisfy two
eligibility criteria:
1. Financial Difficulty – the company must be
encountering, or be likely to encounter, financial
difficulties that affect its ability to carry on as a going
concern.
2. Compromise or Arrangement – the plan must
involve a compromise or arrangement between the
company and its creditors and/or shareholders to
restructure its obligations.
Once an RP is proposed, it must go through a
structured approval process via the Court. The
significant involvement of the Court means the costs
associated with RPs are typically high, and this may
explain why we have not seen a great deal of them.
The Court needs to determine whether the RP is fit
for consideration, including the appropriate classes of
creditors and shareholders. The affected creditors and
shareholders are then divided into classes and asked
to vote on the RP. At least 75% in value of creditors
in each class must vote in favour but even if the RP
receives the required votes, the Court must assess its
fairness before granting final approval.
One of the most powerful features of an RP is the
cross-class ‘cram-down’, which allows the Court to
sanction an RP even if one or more creditor classes
vote against it. This mechanism ensures that RPs can
proceed even if faced with creditor opposition. This
makes them a highly effective restructuring tool, but it
also makes them quite controversial.
If we are to compare the RP to a Company Voluntary
Arrangement (CVA), for example, the RP can proceed
even if creditors vote against it should the court
approve it, whereas in a CVA, it cannot proceed
without the creditors’ approval (75% of creditors’
support is required) and it does not require the court’s
involvement.
Impact on creditors
An RP can have a significant impact on creditors, from
loss of control by the cross-class ‘cram-down’ feature,
to your debt being compromised. This means you may
have to accept reduced payments, extended repayment
terms, or even full debt write-offs.
Should you be faced with an RP, you should seek
assistance to understand what the RP is proposing for
you and your class of creditors. Where possible, you
should negotiate new terms of business, and you
should ensure you vote in the RP process.
You should also monitor the outcome of the
Court’s decision on the RP as it is the Court
that has the final say.
Author: Giuseppe Parla is a Business
Recovery Director and Licensed Insolvency
Practitioner at Menzies LLP.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 11
CONSUMER CREDIT
MIND
GAMES
How can the credit industry respond and fulfil
its responsibilities to its vulnerable customers?
BY STEPHEN KIELY
IN March, Chancellor Rachel Reeves
announced her Spring Statement,
including plans to cut and freeze Universal
Credit incapacity benefit payments for
new claimants, who have been assessed as
too unwell to work due to experiencing
poor mental health or other conditions.
These payments will be cut by 50% compared to
payments for existing claimants, and will be frozen
at this rate until 2030. Naturally, this decision has
become a significant political issue, with concerns
that some households could struggle under the new
arrangements. One notable phenomenon, however,
was the increased emphasis on mental health, and the
relationship of debt to consumers’ wellbeing.
Hammer blow
Responding to the Spring Statement, Helen Undy,
Chief Executive of the Money and Mental Health
Policy Institute, spoke for many commentators when
she said that the announcement amounted to ‘another
hammer blow’ for people who are struggling with
their mental health and finances.
“Incapacity benefits are a lifeline for people who have
been assessed as too unwell to work due to their mental
or physical health,” she said. “Cutting these payments
and freezing them, while the cost of everyday essentials
continues to rise, effectively penalises people for
becoming sick, and the Government’s own estimates
show this reform package will push an additional
250,000 people into poverty.
“This hardship can make it harder to recover and
to return to work, risking undermining, rather
than boosting, the Government’s efforts to grow
the economy. It will also pile on more anxiety and
fear for many people with mental-health problems
who are still reeling from the plans to cut Personal
Independence Payment (PIP) announced.”
Meanwhile, in April, the Welsh Government began
a 12-week consultation to extend enforcement rules.
At the moment, missing a council tax payment means
residents can become liable for the full annual bill
if they do not pay within seven days of receiving
a reminder, and the requirements on councils for
sending reminders and final notices are considered to
be too complex.
The consultation proposes that people will be given
more time to recover from unexpected financial
setbacks, highlighting the potential impact on mental
health.
Cabinet Secretary for Finance and Welsh Language,
Mark Drakeford, said: “I know councils want to help
wherever possible, and we will spread the best practice
we have seen through this fairer framework. This will
help councils differentiate between people who are
struggling and those who are persistently disengaging.
A longer timeframe also allows households to recover
from unexpected events or circumstances that may
have contributed to their financial struggles.”
Bespoke training
This is an issue which is clearly high on the agenda
for many in the industry. Virgin Money recently said
that it had launched a bespoke training programme
for all its 4,000 customer-facing colleagues to equip
them with the skills to support and talk to customers
about their money worries and mental health. It
is working with mental-health charities Mind and
SAMH (Scottish Action for Mental Health).
The new five-module training programme covers
key areas including: understanding mental health;
how to engage in sensitive conversations; and helpful
conversation examples and language to avoid. It also
covers duty of care and how to raise a welfare concern,
as well as how to recognise their own mental wellbeing.
Virgin Money commissioned research showing that
financial pressures are impacting people’s mental
health, with over half (52%) of adults reporting feelings
of anxiety, 45% experiencing stress, and 27% feeling
depressed due to money worries.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 12
CREDIT MANAGEMENT
“CUTTING THESE PAYMENTS AND
FREEZING THEM, WHILE THE COST OF
EVERYDAY ESSENTIALS CONTINUES
TO RISE, EFFECTIVELY PENALISES
PEOPLE FOR BECOMING SICK’’
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 13
continues on next page >
CONSUMER CREDIT
Household bills and the rising costs of everyday
essentials are driving this heightened anxiety, and 66%
of adults worry that the cost of living will rise again,
while 57% fear that essential household items and
paying bills will become unaffordable in the future if
prices continue to increase.
Syreeta Brown, Group Chief People and
Communications Officer at Virgin Money, said:
"We understand the impact financial worries can
have on mental health, which is why it is important
for us to ensure our colleagues can offer the best
possible support to any of our customers facing these
challenges.”
Andrew Berrie, Head of Corporate Partnerships at
Mind, added: “Financial pressures can significantly
impact mental health and with the ongoing costof-living
crisis, these pressures are only increasing.
This programme will ensure vital support is available
to customers, making a real difference for those
struggling with their mental health.”
Weather vane
The industry is eager to get across the message that
help is at hand. Rebecca Nunn, Senior Manager at
Fidelity International describes mental health as
being like the weather, in that it can be unpredictable
and might change for all sorts of reasons – some of
which are within our control, some not.
She insists there are measures that people can take to
help with poor mental health as some diagnoses are
more preventable than others. From awareness and
education at one end of the spectrum, to supporting
people who are more likely to develop mental-health
problems and helping people with mental ill-health to
stay well by empowering them to manage their wellbeing
to reduce the risk of relapse.
“WE WANT FIRMS
TO BUILD ON
THE GOOD WORK
IDENTIFIED, TO
HELP PEOPLE
OPEN UP AND
MAKE SURE THEY
GET THE SUPPORT
THEY MAY NEED.”
While many are making significant efforts, research
by the Money and Mental Health Policy Institute
suggests that more needs to be done to support
people experiencing the long-term cycle of money
and mental-health problems. It concludes that an
extended struggle with either mental or financial
health ‘heightens the probability of one impacting the
other’.
Specifically, the report examined how people aged 25 to
54 experienced this combination of issues differently
depending on whether they faced them on a shortterm
(one to two years) or long-term basis (three or
more years). People who experienced mental-health
problems for three or more years faced significantly
worse income, employment and debt outcomes.
In particular, the report highlights that people
aged 25 to 54, who had long-term mental-health
problems in this period, were nine times more likely
to have struggled financially than people who have
never experienced a mental-health problem. This is
significantly higher than people with shorter mentalhealth
problems, who were just over three times
more likely to have struggled financially than people
without mental-health problems.
It also found that they were 11 times more likely to
have been out of work due to illness or disability than
people without mental-health problems. Again, this
is a significantly higher likelihood than for those who
experienced mental-health problems for a shorter
period of time, who were five times more likely to be
out of work than those without such problems.
The report identified other alarming trends. People
within that age group were more likely to have had low
incomes – with an average income gap of £3,360 a year
compared to people without mental-health problems.
For people with shorter-term problems, the average
annual income gap was £2,376 compared to those who
have not experienced such difficulties. They were also
four times as likely to have been behind on bills than
people without mental-health problems. In contrast,
people who experienced mental-health problems for a
shorter period of time were nearly twice as likely to be
behind on bills than those who have not experienced
problems.
Opening up
Just as financial firms are taking their responsibilities
seriously, however, there needs to be a partnership,
with vulnerable customers opening up to firms in
order to get the right support.
Understandably, this is a difficult issue to approach.
Recent Financial Conduct Authority (FCA) research
finds that just four in 10 vulnerable customers say they
have disclosed their needs to their financial services
provider.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 14
CREDIT MANAGEMENT
However, those that do open up tend to have better
experiences. Three-quarters of vulnerable customers
who told their firm about their circumstances said
that staff asked the right questions to understand
their situation, six in 10 said their firm ‘cared’, and 58%
said their firm took action to provide support they
needed.
On 7 March 2025, the FCA published a review and
good and poor practice examples to further help
firms provide the right care consistent with the
Consumer Duty. Sarah Pritchard, Executive Director,
Competition, Markets and International, said: “It
can be hard to tell your bank or insurer about your
specific needs, but those who ask for help tend to feel
more supported. We have seen good examples where
financial firms are making a difference for vulnerable
customers, but we know that vulnerable people report
more negative experiences than others.
“We want firms to build on the good work identified,
to help people open up and make sure they get the
support they may need.”
Supporting colleagues
Such support for vulnerable customer is, without
doubt, essential, but it can also take its emotional
strain on collections professionals, who need to deal,
sensitively, with difficult cases.
In response, in 2022 NatWest began a collaboration with
JAAQ, an online mental-health platform, powered by
AI. This gives colleagues access to respected mentalhealth
professionals to have their own questions
answered. They are presented with video responses
from over 40 experts, including David Veale, Professor
in Cognitive Behavioural Psychotherapies at Kings
College and Dr Erin Brown, Consultant Psychiatrist in
Early Intervention in Psychosis.
Jen Tippin, now Group Chief Operating Officer at
NatWest, said: “The wellbeing of our employees is of
fundamental importance at any time, but particularly
when faced with concerns around cost of living. My
team is focused on ensuring that employees have access
to the right resources and support.”
Conclusion
After many years of secrecy, mental health is finally
becoming less stigmatised and more openly discussed,
and with that comes an expectation that the finance
industry will take its responsibilities seriously and offer
adequate support – both for customers and colleagues.
Many, in the industry, are making significant
efforts, but there is still much to do to understand what
help is needed, when, and how it can best be offered.
Author: Stephen Kiely is a freelance business writer.
Ways to care for your mental health when
you have money worries – guidance from
the NHS – Every Mind Matters.
• Be kind to yourself – self-compassion is vital for our
mental wellbeing, especially in tough times, and getting
into the right mind space can help before dealing
with money problems. If you are struggling to cope
with money or unemployment, accepting that things
might be outside your control, or take time to sort
can help you feel calmer. Try to treat yourself kindly
and avoid negative self-talk or unhelpful thoughts.
It can also help to remember that things change. Try
cognitive behavioural therapy (CBT) techniques, such
as focussing on what you can control.
• Talk about your money issues – it can help to talk
about your money worries with someone you trust,
like a friend or family member. You might prefer to
talk to someone confidentially, perhaps to work out
how you feel right now or what to do next, like getting
money advice.
• Switch off from money worries – relaxation techniques
and meditation can help us feel calmer, which might
help with feelings of anxiety about money. Taking time
to pause and focus on our breathing can help us feel
more present – even taking a few deep breaths in and
out can help.
• Create good self-care routines - sticking to a routine
might give us a sense of purpose and boost our mood.
This can be tough if you are feeling low, so start with
simple things, such as getting up and going to bed at
the same time every day. As you stick to your routine,
you should notice that your mood starts to improve.
Perhaps start building more into your routine as you
go along, like planning something social or fun, or
trying to exercise more.
• Face unemployment fears – our mental wellbeing can
take a hit if we are not working. A job is often vital
to our financial wellbeing and security – and our selfesteem.
It might also give us a sense of achievement,
a feeling of belonging, and be an important social
network, which helps with feelings of loneliness.
Taking practical steps for our mental health, which we
use every day, can help us build resilience. This could
include having a good self-care routine, exploring
unhelpful thoughts, and looking for solutions to
problems that are within our control.
• Maintain physical health to help ease anxiety - our
physical health often affects how we feel emotionally
and mentally. Being active can really help when we
are dealing with stress caused by money problems and
work issues. Try to be active and stick to a healthy diet.
• Create a budget or money plan – aim to set a regular
time to look at your costs, so you can work out what
you can spend each week or month. It might also help
you identify whether you can save a bit of money,
perhaps for covering unexpected life challenges, such
as replacing an expensive household item.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 15
SANCTIONSW
POTENTIAL
RED FLAGS FOR
SANCTIONS
EVASION ARE
SET OUT IN
ALERTS ISSUED
BY THE NATIONAL
ECONOMIC CRIME
CENTRE.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 16
CREDIT MANAGEMENT
CUTTING
IT FINE
FCA fines – are your controls up to scratch?
BY JOCELYNE GIRGIS AND
ANDREW NORTHAGE
LAST October (2024), the Financial
Conduct Authority (FCA) fined
Starling Bank just under £29m for
inadequacies in its financial sanctions
screening processes, citing ‘shockingly
lax’ financial crime controls which
left the financial system wide open to
criminals and those subject to sanctions.
Over the last couple of years the FCA has been ramping
up its enforcement and has issued several fines in response
to banks' failures to prevent and control financial crime.
The action against Starling highlighted once again the
importance of making sure financial crime systems and
controls are robust enough to stand up to scrutiny.
Core commitment
There's no escaping it, reducing and preventing financial
crime is one of the FCA's core commitments, detailed
in its 2024/25 Business Plan. When considered against
the backdrop of macroeconomic challenges, including
ongoing conflicts and the lingering effects of Brexit and
COVID, the urgent need for healthy financial sanctions
screening processes is brought into sharp focus.
Given the background, it makes sense to look at what's
been happening, including coverage of the latest updates
to the FCA's Financial Crime Guide (FCG), the risks to a
business and what firms should be doing to ensure their
financial crime controls are up to scratch.
What's been happening?
The FCA has hit banks with some of its biggest fines
of late. Examples include the £108m penalty against
Santander UK in 2022 and £265m penalty against
NatWest in 2021, both relating to serious gaps in antimoney
laundering controls.
The action against Starling follows a 2021 FCA review of
financial crime controls at challenger banks. The review
uncovered issues ranging from failures to consistently
apply enhanced due diligence checks, to underdeveloped
risk assessment frameworks and inadequate management
of financial crime change programmes. In Starling's case,
the FCA identified particular concerns with anti-money
laundering and sanctions frameworks, exacerbated by
Starling's notable growth – the systems designed to
address financial crime couldn't keep up.
This activity by the FCA reflects a proactive approach
to meeting an evolving financial crime landscape
head on. Towards the end of last year, the FCA also
released a policy statement detailing changes and
updates to its FCG. The amended FCG applies to all
FCA financial crime supervised firms, or any firm
otherwise supervised under the Money Laundering,
Terrorist Financing and Transfer of Funds (Information
on the Payer) Regulations 2017 (Money Laundering
Regulations).
Updates addressed a number of topics:
Sanctions
The FCA updated the terminology around sanctions
for improved consistency and clarity on key subject
areas such as management accountability for sanctions
governance, cryptoasset businesses, and manual versus
automated sanctions screening processes.
The FCA also provided further clarification on which
suspected sanctions breaches would require FCA
notification (for example, those arising from significant
failings in screening systems and controls) and hinted at
future guidance on enhanced reporting requirements for
significant breaches.
Updates were also made surrounding sanctions screening
processes. In particular that depending on the nature of
a firm's business and assessment of risk, the investigation
of alerts must form a part of the process. Screening
processes may vary firm-to-firm, and screening against
published sanctions lists alone may not be sufficient
to identify potential sanctions evasion involving third
parties.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 17 continues on next page >
SANCTIONS
As referenced in the changes to the FCG, potential red
flags for sanctions evasion are set out in alerts issued by
the National Economic Crime Centre.
There's also now a reinforced expectation that firms will
perform ‘lessons learned’ exercises following sanctions
developments and that senior managers take ‘clear
responsibility’ for managing sanctions risks, firms are
‘actively engaged’ in addressing non-compliance risks;
and firms are ‘sufficiently aware’ of their sanctions
obligations.
Although unlikely to be sector-specific, future sanctions
screening guidance anticipated from the FCA will
include updated examples of good and poor practice,
more case study examples to assist firms with evaluating
their controls, and further references to guidance from
the Office of Trade Sanctions Implementation and nonfinancial
sanctions.
Proliferation financing
Although captured previously in its chapter on
sanctions, the FCG now refers explicitly to proliferation
financing. This update reflects the 2022 amendments to
the Money Laundering Regulations, which now require
risk assessments and controls to be in place for the
identification of proliferation financing risks.
Transaction monitoring
New examples of good and bad practice when using
transaction monitoring systems have been provided with
reference to the use and impact of artificial intelligence
(AI) in increasing transaction monitoring efficiency.
Revisions to the guidance have ultimately been designed
to balance existing regulatory expectations with the
increasing use of AI.
Examples of good practice include tailoring monitoring
system rules to the business, risk and relevant typologies
to ensure accuracy of outcome, regularly testing and
reviewing transaction monitoring system parameters,
and recording any reasons for the decommissioning of
automated systems.
In contrast, examples of poor practice include uncritical
reliance on automated systems or systems which are
not calibrated to specific needs, and dependence on
threshold-based transaction monitoring approaches.
Consumer duty
The FCG has been updated to align with the Consumer
Duty for new and existing products and emphasises
the obligation on firms to provide better outcomes
for consumers. This is particularly pertinent where a
situation raises issues of unfair client treatment which
conflict with due diligence requirements, asset freezing
or risk-based approaches.
To assist businesses with balancing financial crime and
consumer duty obligations, firms are encouraged to
BUSINESSES IN THE
FINANCIAL SECTOR
SHOULD REMAIN
AWARE OF THE
RISKS TO THEM
WHEN CONDUCTING
SANCTIONS
SCREENING.
consider FCA Principle 12 – ‘a firm must act to deliver
good outcomes for retail customers’ – in tandem with the
associated cross-cutting rules. While the Consumer Duty
recognises that not all harms are foreseeable, which is
especially true in the context of newly emerging financial
crime obligations, the duty means that businesses are
expected to consider the necessary action to take once a
harm does become foreseeable.
Data security
The FCG has been updated to include self-assessment
questions on data systems and management, along with
examples of good and poor data security practice. The
FCA has also added links to the National Cyber Security
Centre's Cyber Security Toolkit for boards and its 10
Steps to Cyber Security guidance. The FCA continues
to monitor data security in the context of generative
AI, with a view to providing subsequent guidance on its
secure implementation.
ECCTA 2023
The FCA has endorsed the implementation of enhanced
anti-money laundering and information-sharing powers
under the Economic Crime and Corporate Transparency
Act 2023. Updates to the FCG encourage data sharing
partnerships between businesses, to share information to
combat economic crime without civil liability, provided
compliance with the UK General Data Protection
Regulation is maintained.
Consequential changes
The FCA has generally amended the practice examples
and self-assessment questions available within the FCG
to reflect updates to UK legislation and to remove
redundant EU references. Other consequential changes
include once again naming firms within case studies to
allow other firms to identify whether they've already
assessed a particular case and its relevance to them.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 18
CREDIT MANAGEMENT
The full extent of changes to the FCG can be read in
the FCA’s Policy Statement PS24/17. The FCA has also
indicated that further updates and more detailed guidance
can be expected on fraud, particularly Authorised Push
Payment scams, synthetic identity fraud and digital
fraud, and the use of AI in detecting financial crime.
Such updates will equip businesses to better understand
and address their compliance obligations in relation
to existing and emerging financial crime risks, thereby
allowing them to tailor their screening tools to match
business risk exposure and meet sanctions screening
needs.
What are the risks to a
business?
Overreliance on automated screening processes
Technology and the automation of repetitive tasks
certainly seems like the bee's knees as it streamlines
processes, frees up resources and saves time and money.
However, the reality is that automated processes are
not always able to align with the nuances of every
circumstance. Individuals, criminal organisations,
corrupt officials and terrorism financiers frequently
change their methods, meaning reliance on static
algorithms without human command risks leaving the
door to financial crime wide open.
Responsibility for failing to prevent financial crime internally
While facilitating any economic crime is undoubtedly
problematic, the fact is one doesn't need to have actively
facilitated crime to be held responsible. The series of
‘failure to prevent’ offences for bribery, tax evasion and
the recently introduced failure to prevent fraud offence
(coming into force on 1 September 2025), means it's now
easier than ever to find oneself in hot water for certain
financial crimes. Large organisations are expected not
only to monitor their customers, but also the activities of
persons associated with the business including employees
and agents.
Reputational damage
Failing to protect a business against financial crime
poses severe reputational risk, particularly for financial
institutions. If a bank repeatedly loses money to fraud, its
ability to keep money safe may be doubted. Association
with illegal activity is likely to lead to negative publicity
and customer distrust.
Increased costs
As the complexity and scope of financial crime regulation
increases, so too do compliance costs. This costs risk is
exacerbated further by rising penalties for compliance
failures.
What can be done?
The action against Starling provides a cautionary
reminder to update and bolster sanctions policies and
procedures. There are a number of practical steps a firm
can take to guard against landing on the wrong side of an
FCA investigation.
Implement strategies to enhance financial crime control
frameworks
An efficient compliance framework serves as a shield to
safeguard the integrity of business transactions. Firms
should make sure that their controls are comprehensive
enough to identify and screen all parties relevant to a
transaction, including the individuals or entities that
may have control over the parties. They should ensure
that their systems can address red flags and that recordkeeping
procedures thoroughly document any decision
making, due diligence and mitigation measures taken.
Ensure risk assessments and due diligence checks are fit for
purpose
Weaknesses in customer due diligence checks, such
as failing to obtain customer income and occupation
information, was one deficiency flagged by the FCA in
its final notice to Starling. The identification of high risk
or sanctioned individuals or entities before transacting
should be a priority. Beyond basic due diligence, firms
should implement enhanced measures when verifying
high-risk customers and ensure that any concerns are
promptly reported to the responsible authority.
Proactively monitor internal policies and processes
Organisations need to use a risk-based approach to
periodically review anti-money laundering and sanctions
screening policies in a way that anticipates future needs.
By identifying the highest compliance risks as early as
possible, any changes or mitigation measures stand a
better chance of being effective. Dealing with financial
crime issues on a reactive basis puts the firm on the back
foot and may mean failing to address triggers before they
escalate into full-blown compliance issues.
Being aware of changing financial crime risks
Lastly, an ever-changing regulatory landscape demands
continual revision and development of financial crime
systems and controls. Employees should also be kept
updated of any such developments with frequent
communication and role-specific training. Firms need to
ensure that the message is adapted to present events.
Summary
Businesses in the financial sector should remain aware of
the risks to them when conducting sanctions screening
and be proactive in taking the appropriate steps to
mitigate those risks. The rules are only going to get
harsher and apart from any sanctions applied, the act
of naming non-compliant firms is never going to be a
positive outcome for businesses.
Author: Andrew Northage is a Partner, and Jocelyne Girgis
is an associate, in the Regulatory & Compliance team at
Walker Morris.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 19
FINANCIAL
FORECAST ON
THE FINANCIAL
FUTURE
A report from the recent Esker-hosted round table.
BY MILICA COSIC
ESKER hosted ‘The Credit Industry: 2025 In Review’ at PwC’s London offices on 9 April, bringing together
industry experts John Payne (Dun & Bradstreet) and Lucy Fulmer (PwC) to share insights on the UK economy,
the Spring Forecast, and sector-specific risks, notably insolvency trends and emerging vulnerabilities.
An insightful panel debate followed, moderated by Luke Sculthorpe (CICM) with contributions from
Natascha Whitehead (Hays), Ray Massey (Tokio Marine HCC) and Martyn Brooke (Esker).
THE year 2024 marked the highest
level of business failures in three
decades, with 24,112 insolvencies –
96% of which were small or micro
businesses. The construction
sector remains particularly
vulnerable, owing to sensitivity
to interest rate fluctuations and increasing labour
costs. And while some improvement is projected,
John forecasts that financial conditions will remain
‘tight’ well into this year. This will be further strained
by new cost pressures, including changes to National
Insurance Contributions, an uplift in the National
Living Wage, and rising inflation, forecast at over 3.2%
this year.
Furthermore, trade tensions between the UK and the
US may result in new tariffs, which could either drive
up prices or dampen the pound, depending on how
the Bank of England chooses to respond. A retaliatory
tariff move or a free trade agreement with the US could,
for instance, flood the market with cheaper imports –
potentially undercutting UK farmers and domestic
producers. Lending is becoming increasingly difficult
to access for SMEs, who are already struggling with
high borrowing costs and dwindling credit appetite
among lenders.
The Spring Economic Statement also painted a
cautious picture: Government plans include £4.8bn
in welfare cuts, a £3.6bn reduction in departmental
budgets, and a 6.4% rise in the energy cap from April
2025. All signs point to a tighter fiscal environment
for the foreseeable future.
Insolvency: Outlook for 2025
Lucy Fulmer, Head of the Creditor Markets Team
at PwC, emphasised that while 2024 was one of the
worst years for insolvencies in recent memory, the
distress is likely to continue – albeit that the most
severe impact may be delayed. While voluntary
liquidations and overall company failures showed
minor percentage changes between early 2024 and
early 2025, the underlying pressures on businesses
remain intense. In fact, in 2024, 98% of insolvency
appointments involved businesses with turnovers
of less than £1 million. While there were notable
exceptions – including high-street names like The
Body Shop and Ted Baker – the brunt of the damage
was borne by smaller firms.
The sectors most at risk in 2025 include retail,
hospitality, construction, manufacturing, automotive,
and business services. Interestingly, even the
previously resilient ‘defensible’ sectors, such as tech,
media, telecoms, and healthcare, are now feeling the
strain. Rising debt and underperformance in these
areas suggest that no sector is truly immune to the
current financial climate.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 20
CREDIT MANAGEMENT
After a tumultuous few years, the UK economy remains
in a state of cautious recovery, though challenges
continue to weigh on businesses and households alike.
While certain sectors – particularly services and
technology – have powered through post-pandemic
turbulence, the economy at large has yet to return
to full pre-pandemic strength. According to John
Payne, Senior Economist at Dun & Bradstreet, the
UK economy grew by 1.4% in Q4 2024, outperforming
expectations and edging closer to its pre-pandemic
average of 1.9%. However, this modest growth is offset
by ongoing structural weaknesses and wider financial
pressures.
Encouragingly, the economy is now 15% larger than
it was in 2019 – principally thanks to the robust
performance of the services sector, the traditional
backbone of the UK. But this recovery hasn’t been
felt evenly across the board. Key industries such as
construction, agriculture, and mining continue to face
difficulties, compounded by post-Brexit disruption
and economic uncertainty stemming from US market
fluctuations.
For households, the impact of the ongoing cost-ofliving
crisis remains a daily reality. Since 2021, wages
and prices have surged by 24% – a rate that previously
took a decade to reach. The sharp climb in living
costs, concertinaed into just four years, has left many
struggling to keep up. Unemployment is also creeping
upwards, with many firms slowing down their hiring
plans amid rising operational costs and continued
economic ambiguity.
Additionally, high-profile restructuring cases – such
as Thames Water in the utilities sector – highlight
broader concerns in areas like real estate and wind
energy. Manufacturing wind turbines, for example, has
been plagued by quality control issues, affecting key
components like rotor blades and gearboxes.
Looking ahead, a mix of geopolitical shifts, AI
disruption, potential inflation resurgence, and
legislative changes could act as further triggers for
distress. Lucy also notes a likely uptick in the use of
restructuring plans, although their effectiveness for
SMEs remains uncertain.
A Fragile Recovery
In summary, while the UK is not in crisis, it’s far from
comfortable. Business conditions remain challenging,
households are stretched, and inflation pressures
continue to loom. The service sector’s strength and
steady GDP growth provide a foundation, but it is a
fragile one.
As 2025 continues, financial resilience – whether in
the form of effective restructuring, targeted lending,
or policy support – will be critical to navigating an
economic landscape that, while no longer in freefall,
still demands caution and adaptability.
LOOKING
AHEAD, A MIX OF
GEOPOLITICAL
SHIFTS, AI
DISRUPTION,
POTENTIAL
INFLATION
RESURGENCE,
AND LEGISLATIVE
CHANGES COULD
ACT AS FURTHER
TRIGGERS FOR
DISTRESS.
The Managing Editor, Sean Feast FCICM, writes: Since
the panel debate, the Insolvency Service has released the
March insolvency figures that show a c30% increase in
administrations, a notable increase since COVID-19. Since
administrations are most popular with larger firms, they
tend to have the biggest impact on creditors and insurers.
While one month’s data does not signify a trend, the figures
are interesting, nonetheless.
At the time of going to press also, the absence of a UK/
US trade deal and/or a UK/EU trade deal also remains an
ongoing concern and brings uncertainty regarding future
economic prosperity. Perception is everything, and with
uncertainty inevitably comes delays in investment and a
fall in discretionary spend, which could do more harm than
any eventual deal could do good. The longer the uncertainty
continues, the poorer it will be for the UK economy.
Author: Milica Cosic.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 21
ENFORCEMENT
TRANSFER FEE
A fair fee for enforcement is long overdue.
BY RUSSELL HAMBLIN-BOONE
IMAGINE if you will, being invited to
invest in a business that was solely dependent
on central and local Government
contracts. However, the business revenue
does not come from your Government
clients. In fact, you must provide your
services to the public sector for free and
your income is not guaranteed.
Now, add in the fact that the prices you can charge are
set by the Government, and an inflationary increase is
not automatic, so your prices have been frozen for over
a decade. That is the reality of the civil enforcement
sector, which recovers debts on behalf of local
authorities and His Majesty’s Courts and Tribunals
Service (HMCTS). This includes council tax arrears,
business rates, road traffic and parking penalties,
magistrates’ court fines, employment tribunal awards,
child support payments, and commercial rent arrears.
The enforcement fee structure was established under
the Taking Control of Goods Regulations 2014. At the
time the regulations were drafted, the Government
commissioned economic analysis to design an effective
fees mechanism. The economist recommended
adjusting fees annually to track inflation. Since the
statutory fees were introduced in April 2014, inflation
has eroded their real value by 24%.
Annual inflation review
The Ministry of Justice included an annual inflation
review and implementation mechanism in the
Explanatory Memorandum to the Taking Control
of Goods (Fees) Regulations 2014, intending it to be
incorporated into the regulations.
The Ministry has acknowledged that infrastructure
and reform costs were not foreseen in the original
2014 statutory fees, including advanced technology for
vulnerability identification and support, body-worn
video, tracking and tracing services, independent
advisory groups, and the Enforcement Conduct
Board.
Ensuring enforcement agents receive appropriate
remuneration is essential for maintaining a sustainable
service and attracting new professionals to the field.
Between August 2017 and January 2023, the number
of certificated enforcement agents decreased by 33%.
There are few instances where private contracts
with public sector bodies have fixed prices. Legal aid
provision serves as a close example; however, many
firms closed due to fees not being increased regularly
enough to prevent market collapse.
This situation also contrasts with significant fee
increases at HMCTS during the same period and with
Scotland, where enforcement fees have increased five
times over the same timeframe.
Civil Enforcement Association CIVEA members
collect approximately £2bn annually in outstanding
debt for numerous local authorities, businesses,
and individuals across England and Wales. CIVEA's
research indicated that civil enforcement prevents
losses to the public purse estimated at £12bn. Effective
debt recovery helps prevent today’s creditors from
becoming tomorrow’s debtors.
Supporting growth
In February, Justice Minister Alex Davies-Jones MP
stated that the enforcement sector plays an important
role in supporting economic growth, funding public
services, and underpinning the rule of law. This
underscores the importance of civil enforcement in
maintaining revenue streams for local governments
and ensuring social justice.
A viable enforcement fee structure is critical to
achieving this. Without it, there is a higher risk of
unpaid debts, leading to decreased confidence in
the system, potential discouragement of investment,
reduced funds for local councils, and jeopardised
economic growth.
The approach to reviewing fees is not new. It was
originally established in the Tribunals, Courts and
Enforcement Act of 2007, introduced by the previous
Labour government, which led to the Taking Control
of Goods Regulations.
This spring, the Ministry of Justice plans to increase
171 court and tribunal fees to reflect changes to
the Consumer Price Index (CPI). However, the
enforcement sector continues to await secondary
legislation to enact a nominal 5% uplift approved by
the previous administration based on 2022 figures.
Timely revisions
The civil enforcement sector faces numerous
challenges due to this outdated fee structure. Without
timely revisions to the fees, smaller enforcement
firms are at risk of collapsing, which would lead to a
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 22
CREDIT MANAGEMENT
MANY DEBT COLLECTION AGENCIES
EXEMPLIFY RESPONSIBLE DEBT
RESOLUTION PRACTICES, AND
THEIR INNOVATIVE APPROACHES
INCREASINGLY LEAD THE WAY IN
MODERN ENFORCEMENT.
monopolized industry dominated by a few large players.
This reduction in competition could result in service
failures and diminish the ability of local authorities
to efficiently enforce debts. Ensuring a viable fee
structure is essential not just for the continuation of
enforcement services but also for maintaining public
confidence in the system.
In addition to debt collection, enforcement agents
play a crucial role in identifying and signposting
vulnerable individuals to welfare support. Last
year, they identified 351,000 vulnerable individuals
unknown to councils. Many debt collection agencies
exemplify responsible debt resolution practices, and
their innovative approaches increasingly lead the way
in modern enforcement.
An industry that stands still quickly becomes
irrelevant. The civil enforcement sector must remain
dynamic and forward-looking, constantly adapting to
new challenges and opportunities. It is imperative to
lead the way in ensuring the industry remains fit for
purpose and enforcement is conducted responsibly.
Given it has been over 10 years since the Taking Control
of Goods Regulations were introduced, it is high time
to review and update the fee structure to better reflect
current economic realities. Governments must seize
this unique opportunity to ensure fair treatment and a
fair fee structure that aligns with the costs of delivering
these crucial services.
Author: Russell Hamblin-Boone is CEO of the Civil
Enforcement Association.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 23
INTERVIEW
FAMILY
TIES
Sean Feast FCICM speaks to two
members of the Advisory Council
with a family connection.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 24
CREDIT MANAGEMENT
Both Josh and Charles
share a love of classic cars
and motor racing.
CHARLES Mayhew FCICM and his
son Joshua Mayhew MCICM have
recently been elected to the CICM
Advisory Council and as father
and son their election is a rarity in
the annals of the Institute’s history.
Sean Feast FCICM caught up with
them both while the pair were en route to their offices
in the United Arab Emirates.
SF: What careers’ advice did you receive at school?
JM: Honestly, I can't really recall ever getting
dedicated careers’ advice whilst at school. I attended
a boys grammar school (Maidstone Grammar School
for boys) and I think that the attitude was very much
steered towards university. I did achieve four A Levels
but when it came to further studying, I already knew
that I wanted to get into the world of work rather
than paying to study for a further three years. At the
time, amongst my peers, this was quite ‘out there’ but
I think it’s definitely much more common today and
certainly paid dividends for me.
CM: I was going to join the police and the school
encouraged it. We had some great role models in
our school including Lorna Duggleby for French and
academic studies (she later became head teacher at
Bromley High School) and Rob Probyn for Rugby.
Both were amazing, encouraging but tough, nononsense
teachers.
SF: What did you want to be when you grew up?
JM: Charles and I have always loved motor engineering
and classic cars/racing so that world always excited
me, but being 6ft 5ins tall and 120kg does not suit a
racing driver, so credit and collections it was!
CM: I wanted to be a Policeman and join the Police
cadets at 16. Unfortunately, by the time I reached 16
they had phased this out, so it wasn’t an option.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 25
continues on next page >
INTERVIEW
Josh was a professional rugby
player and still has a passion for
the game.
SF: How did you get into the world of credit?
JM: Inevitably, through Charles, somewhat. I worked
at ASDA through my sixth form studies and as soon
as school was finished, I applied at Cabot Credit
Management as it was close to the family home and I
already knew a few people there through the local area
and Dad. I worked there for more than three years,
latterly as a pre-litigation officer. (Josh spent his first
four months within Cabot’s collections department
before being asked to join FIRE Ltd in August 2010.
This was Cabot’s last stage of telephone collections
and, after a merger in June 2012 with Morgan
Solicitors, also its in-house litigation department. He
dealt primarily with the settlement of defaulted and
ongoing debts, alongside dealing with accounts post
litigation action.)
CM: A sales career dropped me into the world of
credit in 1994, working for STA Graydon. (Charles
spent almost 10 years with the business at the start
of a career that now spans more than 30 years. He
has been a European Board member of ICTF, the
owner/director of Moreton Smith, and is a partner at
CoCredo.)
SF: What do you do now/what is your current role?
JM: I am Managing Director at Global Credit
Recoveries, helping to recover funds globally on a no
recovery, no fee basis. I am also Chair of the CICM
Kent Branch and sit on the Advisory Council for the
CICM. I am also a husband, and dad to a fantastic
two-and-a-half-year-old daughter.
CM: I am CEO of Global Credit Recoveries, a role I
have had since August 2018, dividing my time between
our offices in London and Dubai.
SF: When did you first come across the ICM (CICM)
and why?
JM: From a young age I have always known of
the CICM, likely from being when I was 16 and
doing work experience at one of Charles's previous
collection agencies. The CICM has played a huge role
in my career already and I sincerely look forward to
the input I can have over the span of my career - if
they keep me around! I first got involved around 2018
when Global Credit Recoveries was conceived, with
a view to networking and knowledge sharing. The
professional network within the CICM is absolutely
immense, and you quickly find that everyone within
the industry is very happy to share their expertise and
their time to helping younger credit professionals
exceed. There are far too many people for me to
mention, but it’s a wonderful group.
CM: I first came across the ICM (as it was then) in
1994. I was establishing an office for Stanley Tulchin
of STA Graydon (the initials ‘STA’ came from Stanley
Tulchin Associates) and he said it would be a good
idea to get involved with the Institute. I have now
been a member for more than 27 years.
SF: As part of the Advisory Council, how do you
think you can help the CICM moving forwards?
JM: I say that the key thing for me to is try and attract
younger credit professionals into the community. It’s
something that appears to be missing a little, especially
with those finishing their studies, but I am pleased to
confirm that the Advisory Council is already working
on this. More to come on that space! It has also been
a pleasure to work with other Southern Branches
creating the annual Southern Branches CICM Event,
which is coming into its third year in September. It’s
getting bigger and better every year! Save the Date –
18 September 2025 at Brands Hatch Racetrack, Kent.
(There’s the racing again....)
I hope that I come across as someone that anyone in
the industry, or hoping to be part of our industry, can
approach with any questions. I am very happy to share
a virtual call, coffee, etc with anyone that’s interested
or has any ideas.
CM: I hope I can contribute by way being an ‘ideas’
person with a keen business acumen, that will help in
promoting the CICM to an even wider audience.
SF: Josh - in your opinion, what are the principal
strengths (i.e. best qualities) of your dad?
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 26
CREDIT MANAGEMENT
THE PROFESSIONAL
NETWORK WITHIN THE
CICM IS ABSOLUTELY
IMMENSE, AND YOU
QUICKLY FIND THAT
EVERYONE WITHIN
THE INDUSTRY IS VERY
HAPPY TO SHARE
THEIR EXPERTISE.
Josh claims that his father, Charles, occasionally gets mistaken for his brother.
JM: We are very fortunate that Charles and I
complement each other very well – he occasionally
gets mistaken for my brother not father, which he
doesn’t let me forget. Operationally, I manage GCR
on the day-to-day, but Charles's wealth of experience
from previous agencies gives us a real advantage
when forecasting our targets and goals. I have a lot
of ambition when it comes to GCR, but Charles is
often the voice of reason - as a result of that mixture of
excitement and tried and tested methods - we have a
business which has beautifully grown organically over
the past eight years.
In saying that though, the decision to open our UAE
office three years ago was one that gave us plenty of back
and forth. Ultimately, when we sat together alongside
our management team, the depth of knowledge and
understanding that Charles has within the region,
matched with the desire to grow our offering globally,
led us to pushing forward with this. This turned out to
be a great idea and that office is now looking to expand
further in 2025.
SF: Charles – in your opinion, what are the principal
strengths (i.e. best qualities) of your son?
CM: He’s hardworking, and has the ability to learn
and adapt, and bring a younger person’s viewpoint
- many of the traits he learned playing rugby (Josh
was a professional rugby player in New Zealand and
Australia).
SF: What would you change about him?
JM: An important thing for both of us is definitely
keeping our mental and physical health in check. I am
always checking in with Charles to ensure that he is
getting his daily swim in and taking enough time to
unwind and relax. With the amount of travelling we
do seeing clients globally (I type this from an Emirates
flight to the UAE) its integral that we do find the time
to relax. I would like him to switch off a little more.
CM: I’d give him more patience and tell him sometimes
to slow down.
SF: If you weren’t doing what you are now, what
would you be/where would you be?
JM: I do believe I would have always found my way
into the credit world, but maybe I would still be trying
to push my rugby career forward. Who knows? I’m
very happy and proud to be working with my dad – I
wouldn’t change it for the world.
CM: I probably would have joined the services,
although at one point I was going to train to be a deepsea
diver.
SF: And that seems a good place to end!
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 27
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driven communication solutions including Docmail
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online or the perfect blend of the two.
Top Service Ltd. The only credit information and
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Key IVR provide a suite of products to assist
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In a credit management environment, these services
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Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 29
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OPINION
ROUGH
JUSTICE
The wrong increase at the wrong time.
BY ROB THOMPSON, FCICM
ON 8 April 2025, some 171 court fees
were increased in line with inflation.
Most were increased by 3.2% to reflect
the increase in the Consumer Price
Index (CPI) over the previous year.
Hearing fees in the fast and multitrack
increased a whopping 13.5%,
representing the increase in the CPI over the last two years.
In normal circumstances, linking court fees to inflationary
increases would not be controversial. It could well be seen
as sensible. However, recent circumstances have been far
from normal. Let’s take a look back over the last decade
or so.
Front loaded
As a starting point, consider that court fees are front
loaded. When issuing a money claim over £10,000, the fee
is 5% of claim value. For claims over £200,000, the fee is
capped at £10,000. Just as well. That is an obscene amount
of money just to issue a claim. It doesn’t cover any further
work, such as court hearings. The vast majority of money
claims conclude with a default judgment, requiring the
bare minimum of administration. It may not be ‘money for
nothing’, but it often comes close.
We then had the introduction of so-called ‘enhanced court
fees’. These enable fees to be charged which exceed the cost
of providing the service. Since their introduction, civil
court users cover the entire cost of the civil courts, plus a
significant contribution to the financing of the family and
criminal courts.
For years, bulk users in the civil courts had been encouraged
to issue their claims digitally. In return, digital issue fees
were discounted. However, as digital claims increased and
paper claims declined, the decision was taken to ‘align’
the fees. Would they align downwards? That would seem
logical, since the mission had been accomplished, and most
claims were now digital. Or would the fees maybe align
halfway between the two? Oh no, court users were then
expected to pay the higher ‘paper’ fee, for the cheaper-toprovide
‘digital’ service.
Lauded reforms
Then we’ve had the much-lauded court ‘reform project’
A supposedly five-year project launched in 2016 and
‘concluding’ last month, some nine years later. Over
that time, we’ve learned what was meant by ‘reform’.
Centralisation, digitalisation, streamlining and cost saving.
No real, fundamental reform of processes, many of which
are decades old and crying out with opportunities for
improvement to deal more effectively with the modern
world.
A civil court system which is arguably now more
fragmented than when the so-called reform started, with
multiple platforms, including the new OCMC alongside
MCOL, but with bulk users left behind and unable to
participate. Systems and processes half-built, partially
online, but still no change to enforcement processes, which
is where the real opportunities were always to be found.
In the meantime, court files are destroyed earlier and
earlier in the name of data security, but the real purpose
clearly being cost saving. Court users forced to recreate
the destroyed court file in order that a further step can
be taken. The court user serving the court service, despite
having paid a fortune for a service which has then been
ended prematurely.
Poor service
Finally, an ongoing poor level of service plumbed even
greater depths following the pandemic and continues to
struggle to recover, with huge delays and administrative
issues only now beginning to be finally brought under
control.
And whilst court fees enjoy the luxury of inflationary fee
increases, the same is denied to private sector enforcement,
who are expected to continue to maintain standards with
ever dwindling margins.
The court service exists to provide justice for the benefit
of court users. It is not there purely to generate revenue
for the state, providing a bare minimum service in return.
That needs to be remembered. In the circumstances, this
was an extremely inappropriate and unjustifiable time for
fee increases.
Author: Rob Thompson FCICM is Chair, Civil Court Users
Association (CCUA).
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 31
COUNTRY FOCUS
on Saudi Arabia
The pitcher
and the well
There is more to Saudi Arabia
than sand and oil.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 32
CREDIT MANAGEMENT
SAUDI Arabia is a relatively new construct
as countries go. Known for its application
of Islamic principles and the birthplace of
the religion, the country is thought of – by
many who don’t really know it – as a place
of just oil and sand.
But of course, there’s more to Saudi Arabia if we consider
the Jeddah Floating Mosque, Arabic calligraphy, the Shada
Mountain caves, desert safaris – either by 4x4 or camel, and
the King Fahd International Airport in Dammam City –
the largest airport in the world.
And let’s not forget that in 2034 the country will be hosting
the FIFA World Cup tournament which will no doubt
provide a fillip for the economy.
A melting ice cap
Evidence of humans in the Arabian Peninsula dates back
15,000 to 20,000 years, living off wild animals and plants.
After the European ice cap melted after the last Ice Age,
the climate became dry; plains once covered with lush
grasslands gave way to deserts.
Located between the Nile River Valley and Mesopotamia,
the Arabian Peninsula became the crossroads of the ancient
world, especially in terms of trade.
The peoples of the region remained largely untouched by
the political turmoil elsewhere with their goods in great
demand regardless of whichever power was dominant.
The early 600s saw the birth of Islam and within 100 years
an Islamic Empire extended from Spain to parts of India
and China. Arabic emerged as the language of international
learning and Muslim scholars made major contributions
to many fields including medicine, biology, philosophy,
astronomy, arts and literature.
Come the 17th century the empire broke up into smaller
Muslim kingdoms and the Arabian Peninsula entered
a period of relative isolation. The First Saudi State was
formed in 1727 and prospered, ruling over the entire central
plateau; by the early 19th century it took in most of the
Arabian Peninsula. Ottoman forces effectively ended the
state in 1818 following an invasion.
A Second Saudi State came into being in 1824 and within 11
years had regained most of the lands lost to the Ottomans.
But a second campaign by the Ottomans, in 1865, led to the
end of that state some 25 years later.
The state’s hierarchy eventually fled to Kuwait where it
stayed until 1902. But a scion of the ruling family then
marched into Riyadh and took control. With the collapse
of the Ottoman Empire, by September 1932, the country
had become the Kingdom of Saudi Arabia.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 33
continues on next page >
COUNTRY FOCUS
The Prophet's Mosque is the second mosque built by the
Islamic prophet Muhammad in Medina, after the Quba Mosque,
as well as the second largest mosque and holiest site in Islam,
after the Masjid al-Haram in Mecca. the Saudi region of the
The Gulf of Aqaba in the northwest separates Saudi
Arabia from Egypt and Israel. Notably, Saudi Arabia
is the only country with a coastline along both the Red
Sea and the Persian Gulf.
Sand covers a significant part of the country – around
33% or 635,000km2. Most of the sand clusters are
concentrated in the east and southeast of the kingdom.
However, there are mountainous areas as well as plains;
mountain ranges traverse the Kingdom's length - Hijaz
and Aseer mountains have peaks above 3000m. But it
is the central region with its deserts and rocky plateaus
that account for 90% of the overall area.
Saudi Arabia has no permanent rivers, and the country
is considered deficient in water.
Growing population
According to the CIA World Factbook the 2024
population stood at 36.5m with males making up
20.7m, and females 15.8m, of the total.
If we look at a UN World Population Prospects, we see
how the population has grown over the years – from
3.91m in 1960, to 10.1m in 1980, and 35.9m in 2020. The
growth rate over the same was 3.2%. 5.06% and 0.47%.
It is now 1.38%
In 1938 they discovered oil. In 1960 Saudi Arabia
helped to found the Organisation of Petroleum
Exporting Countries (OPEC) and in 1973 led an oil
boycott which saw a quadrupling of the price. In 1990
Saudi Arabia asked the US to intervene in the Iraqi
invasion of Kuwait. In recent years the country has
liberalised – a little.
Central geography
The Kingdom is located in the centre of the Middle
East and is bordered by the Red Sea to the west;
Jordan, Iraq, and Kuwait to the north; the Persian
Gulf, Bahrain, Qatar and the United Arab Emirates
to the east; Oman to the southeast; and Yemen to the
south.
As for area, Saudi Arabia is placed 12th in the global
rankings with 2.15m km2. It sits below the Democratic
Republic of Congo (2.34m km2) but above Mexico
(1.96m km2). The usual comparison with the UK shows
it a minnow being placed 78th with just 244,376 km2.
The population pyramid is mostly what one would
expect from a modern country – it has narrow base
with a minor bulge at age 10-14 which constricts again
before expanding once more in the 30-49 age bracket.
From there on it tapers to age 60 and markedly more
so to age 89. In general, the age brackets are reasonably
symmetrical with one exception – a huge imbalance
in favour of males between 35 and 49. This has been
largely explained by SpringerLink which noted that
‘the very high sex ratios of Arabian Gulf countries are
… due to excess male labour force from East Asian and
African countries.’
Ethnically speaking, the CIA reckons – logically
– that it’s 90% Arab and 10% Afro-Asian. Arabic
is the official language. However, Australia-based
Cultural Atlas reckons that Arabic is spoken by 51.6%
of the population, English by 16.2%, Urdu by 14.8%,
Malayalam by 7.4%, and ‘other’ by 8.9%.
As to where the population lives, until the 1960s,
most were nomadic or semi-nomadic. But due to
rapid economic and urban growth, more than 95% are
now settled and 80% of Saudis live in 10 major urban
centres.
According to Investment Monitor, using December
2022 data, Riyadh has 7.68m residents, Jeddah 4.7m,
Mecca 1.58m, Medina, 1.18m, Dammam 1.25m, Al-
Mubarra 837,000, Taif 695,000, Tabuk 670,000,
Buraydah 669,000, and Jubail 680,000.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 34
CREDIT MANAGEMENT
x Sindalah is a luxury
island destination
in Tabuk Province,
Saudi Arabia, home to
kaleidoscopic-coloured
coral reefs and an
abundance of diverse
marine life.
It’s worth noting that Saudi Arabia employs millions
of foreign workers. Argaam.com reported in January
2025 that the number of workers reached 17.2m by the
end of Q3 2024 (General Authority for Statistics).
Most of the workers in Saudi Arabia are in the private
sector (66%), followed by Government (7%), public
sector (3%), and domestic workers (23%).
The number of foreign workers in Saudi Arabia
reached about 13.2m, representing 77% of the total;
Saudi workers numbered four million, or 23% of the
total.
Saudi Arabia is, it should be said, building a new city
at the north end of the Red Sea, Neom, at a cost of
some $8.8tn. It’s expected to be completed by 2039.
Expanding economy
Worldmeters, using 2023 data, places Saudi Arabia’s
economy as the 19th largest in the world with a GDP
of $1.06tn. Turkey is 18th ($1.18tn) and Switzerland
is 20th ($884.9bn). In comparison, Canada is 10th
($2.14tn), UK 6th ($3.37tn) while the US is placed first
($27.7tn).
If we look at growth rates, the World Bank details some
spectacular rates and a dramatic peak (52.6% in 1970)
and less dramatic trough (-16.1% in 1980). There have
been the odd years of sub 1% growth, but in general,
anywhere between 5% and 11% is normal for Saudi
Arabia. In comparison, the UK has seen peaks and
troughs, but which maintain a sawtooth profile with
highs until 2000 of around 5% and lows of -2.5%. But
over the last 25 years the peaks have been nearer 3%.
And as for inflation, apart from a 34.58% peak in 1975
Saudi inflation appears generally stable at no more
than 5%.
Business sectors
Oil and gas
Not unsurprisingly, oil and gas are the bedrock of
the Saudi economy. The US International Trade
Administration, citing OPEC data, says that the
Saudi’s possess around 17% of the world’s proven oil
reserves and the country is one of the largest exporters
of oil.
An IMF publication, Saudi Arabia: 2024 September
Article IV Consultation-Press Release; and Staff
Report, published February 2025, noted that oil
accounts for approximately 30% of Saudi GDP and
55% of Government revenue – subject to substantial
fluctuations depending on oil prices - each year.
However, the Government has seen the future and is
looking at a net-zero economy by 2050. It is investing
in areas such as cleaner conventional engines, carbon
capture, utilisation and storage, hydrogen, and
renewables.
State producer Saudi Aramco reported a workforce of
approximately 75,100 in 2024, up from approximately
56,000 in 2011. Given the size of the company, it needs
to spend well in terms of capital expenditure. Indeed,
the US noted that in March 2023, Aramco had set a
capital expenditure goal of $45-$55bn in FY2023 to
support an increase in oil production to 13m barrels
per day by 2027. Opportunities exist in relation to
exploration and production, equipment and services,
and refining.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 35 continues on next page >
COUNTRY FOCUS
Ca
It’s well known that the country is on a journey of
reform. As part of this, in 2018, the Government
ended a 30-year ban on cinemas. Consequently, by
April 2022, there were 56 cinemas and a Media City
in Riyadh. Allied to this are theme parks, live events,
and sports-related infrastructure.
Chemicals
With ready availability of raw materials, Saudi Arabia
has a chemicals sector run by Saudi Aramco.
In 2024, Management consultants IMARC Group
reported that the country’s speciality chemicals
market size reached $7.2bn in 2024. Looking forward,
IMARC Group thinks that figure will rise to reach
$10.4bn by 2033 following a growth rate of 4.17%
between 2025-2033. Fundamentally, it says the need
for high-performance and function-specific chemicals
across different end use industries, such as oil and
gas, pulp and paper, personal care, etc., is primarily
driving the market growth.
Interestingly, Mordor Intelligence thinks that the
market was worth $11.29bn in 2024 and will worth
$15.20bn in 2030. One of the two reports may be right.
The move away from oil is well documented in Vision
2030 – the country’s plan to reduce its dependence on
oil, diversify its economy, and develop public service
sectors. However, CityAM wrote, in July 2024, ‘the
plan doesn’t mean by any sense that manufacturing
and the production of vital raw materials will fall
away. In fact, one of Saudi’s most thriving sectors is
the chemicals industry, which employs some 89,000
and provides indirect employment for at least three
times as many across the Kingdom.
Construction
With the development of Neom and other projects,
this sector has grown somewhat. Big 5 Construct Saudi
reckoned that by the end of the fourth quarter of 2022,
the sector in Saudi Arabia employed approximately
2.46m workers (those covered by social insurance
regulations). The sector was valued at $120.4bn in 2021
and between 2023 to 2026 should grow by 4% a year
according to a report from Gulf Business.
The reason for the growth is the substantial
investments in transportation, renewable energy,
housing, and tourism projects, aligned with the
Vision 2030. Big 5 Construct Saudi sees construction
as playing a pivotal role in this, especially as there are
over 5,200 ongoing projects worth a combined total
of $819bn.
Tourism
The US Government highlights that travel, tourism,
and entertainment is a priority sector under Saudi
Arabia’s Vision 2030 plan.
Saudi Arabia’s plans suggest that there will be more
100m visitors annually by 2030. It is facilitating the
opening of its UNESCO World Heritage sites, the
construction of resorts on its Red Sea coast, and the
launch of a cruise line. The country is investing in
sports teams, infrastructure, and events at home and
abroad, from football to golf to Formula 1 to video
games – and the World Cup. There’s also the annual
Hajj pilgrimage with 2m visitors. But the jobs created
by the Hajj are temporary. It generates $2–3bn in
revenue.
Argaam.com states that the number of workers in
the tourism sector increased by 5% year-on-year to
approximately 959,200 workers in Q2 2024. And the
World Travel and Tourism Council reported that the
sector contributed $131.9bn to the Kingdom's economy
in 2024, representing 12.45% of GDP.
Other
Despite being a desert, largely, Saudi Arabia has
regions where a small agricultural sector can thrive –
one that is worth, according to Mordor Intelligence,
$19.75bn. It is the world’s largest exporter of dates
(in 2022, $341.5m from a volume of 321,000 tons). As
for other products, in 2021 Report Linker said barley
production was 673,100 tons, and in 2025, World Grain
reckons that wheat production will be 1.5m tons.
There are other aspects to the sector with millions of
head of sheep, goats, camels and cattle.
Saudi Arabia possesses some minerals – gold,
silver, iron, copper, zinc, manganese, tungsten,
lead, sulphur, phosphate, soapstone, and feldspar;
resourcegovernance.org reckons that the estimated
value of unexploited mineral resources in Saudi
Arabia is around $2.5tn (2024). And as part of its
goal of economic diversification and reduce reliance
on oil, Saudi Arabia aims to increase the mining
industry’s GDP contribution from $17bn to
$75bn by 2035.
Summary
Saudi Arabia is clearly a country of
vast wealth that is transitioning away
from a dependence on oil. Given
its position in the Middle East, it
would be foolhardy to ignore it as
a destination for export. However,
visitors need to very carefully
observe its laws and etiquette.
Author: Adam Bernstein is a freelance
finance writer for CM magazine.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 36
BRANCH NEWS
FRESH VISION
AND PURPOSE
The CICM North West Branch Re-launch.
ON a bright and sunny afternoon
in Manchester, the CICM North
West Branch marked a significant
milestone with an official re-launch
event held at the Hays office on
10 April. A warm thank you to
Hays for graciously hosting us and
providing a fittingly bright backdrop for what proved to
be a vibrant and optimistic occasion.
This was more than just a gathering; it was the first step in
revitalising the branch and reaffirming our commitment
to serving credit professionals across the region. We are
sincerely grateful to all who attended and contributed to
such a promising start.
We’re excited to share our refreshed vision and goals as
we look ahead. Our aim is to become the leading branch
in the CICM network. At the heart of this ambition is
our commitment to putting members first—your voice,
feedback, and participation will shape everything we
do. We’re also keen to bring branches together more
often, with joint events and greater opportunities
for networking. Together, we believe we can achieve
remarkable things.
We are pleased to introduce the new committee guiding
this renewed direction: Paul Quinti FCICM serves
as Chair, Laurie Beagle FCICM takes on the role of
Secretary, and Jacqueline Hitchen FCICM (Grad) joins as
Treasurer. Supporting the leadership team are committee
members Chris Hardman MCICM, Peter Gent FCICM
(Grad), Xerxes Stallworthy ACICM, and David Thornley
FCICM (Grad).
recovery, and insolvency was delivered by Ross and Kevin
Lucas of Lucas Ross Ltd. The event concluded with an
open forum where members were invited to share their
ideas and expectations for the branch going forward.
Looking ahead, the 2025 event calendar is already shaping
up. Plans include a virtual event (date to be confirmed),
Credit Fest on 23 September, a joint branch event in
October, and a festive end-of-year social. Networking
opportunities will continue throughout the year to help
members connect, collaborate, and grow.
We’re thrilled with the energy and enthusiasm that
marked this re-launch. Thank you once again to everyone
who supported the event—and to our generous hosts and
brilliant speakers. If you didn’t receive an invite this time,
let us know and we’ll make sure you’re included in our
future events.
Author: Laurie Beagle FCICM.
The day featured a rich programme of presentations
and discussion. Chair Paul Quinti opened with an
overview of our branch’s new direction, followed by a
recruitment update from Natascha Whitehead FCICM,
Senior Business Director at Hays, who shared insights on
navigating market challenges. Luke Sculthorp FCICM
brought news from CICM HQ, offering a look at what’s
in store for 2025. A compelling session on business rescue,
Dear Branch Members,
If you have a branch event that you would like to be featured in the CM magazine, please submit your article to the Art Editor.
Articles should be no more than 400 words, and if you are providing images, they must be of high quality for print.
Please note that inclusion is subject to space and the editor’s approval. We look forward to showcasing your branch activities!
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 37
ENFORCEMENT
REMEDIAL
ACTION
Why backing the Civil Justice Council’s
Enforcement Report matters.
BY ALAN J. SMITH
HIGH Court Enforcement Officers
Association (HCEOA) is calling
for action to implement the recommendations
of the Civil Justice
Council’s (CJC) recent report on
Enforcement as it will benefit
creditors, debtors, and the wider
justice system.
The CJC’s newly published report on enforcement
represents a significant step forward in efforts to
modernise and improve the way judgments are enforced
in England and Wales. As a profession with deep,
practical experience of what works in practice, the
HCEOA has welcomed the report’s impartial, balanced
recommendations and is urging the Government to take
swift action to bring about the reforms outlined.
For those unfamiliar with the workings of the enforcement
sector, it’s easy to overlook the pivotal role it plays in
supporting the rule of law and underpinning economic
confidence. When people and businesses are awarded
judgments, they have the right to see those judgments
enforced effectively. Without a fair and functioning
enforcement system, the justice process breaks down, and
trust in the system starts to erode.
That’s why the CJC’s aim of delivering ‘a fair and effective
enforcement system’ resonates so strongly with us. It’s also
clearly something that aligns with public expectations:
Our 2024 perception research showed that 83% of
respondents agreed or strongly agreed that enforcement
is a necessary part of the justice system.
At the heart of the report is a long-term recommendation
for the creation of a single unified digital court for the
enforcement of judgments. We support this goal in
principle. As with any reform, the devil is in the detail.
It’s crucial that such a digital system gives creditors
real choice, including the ability to select High Court
enforcement if that is the most appropriate and effective
route. For this to happen, the government must act
on the report’s recommendation to bring Part 4 of the
Tribunals, Courts and Enforcement Act 2007 into force.
Doing so would provide enforcement professionals and
creditors with controlled access to important financial
information about debtors, helping everyone involved to
make informed, fair decisions.
One of the more immediate recommendations in the
report addresses the current pressures on the County
Court system. Anyone familiar with day-to-day court
operations will know that the County Court is under
severe strain. The report reflects this reality, describing
the system as ‘under-resourced and overburdened’, and
highlighting widespread concerns among court users.
There’s a straightforward, practical solution that would
help – give creditors the choice to use High Court
enforcement for debts under £600. Currently, these
smaller debts must be enforced through the County
Court. This is a change we have long championed, and
it’s one that court users clearly support. Our ‘Freedom of
Choice’ research found strong backing for this proposal,
which can be implemented without additional cost to the
debtor by using the non-High Court fee scale.
This is not about pushing out County Court bailiffs
– it’s about relieving pressure on the system and
providing more effective service for everyone. That
includes protecting vulnerable debtors. The CJC rightly
emphasises that any extension of HCEOs’ powers must
come with robust safeguards. These safeguards already
exist. National Standards issued by the Ministry of Justice,
the Enforcement Conduct Board’s (ECB) new standards
and independent complaints procedures, and oversight
mechanisms all work together to ensure accountability
and fairness.
Of course, the CJC’s report goes beyond High
Court enforcement. It includes a series of broader
recommendations, such as simplifying court forms and
making legal language easier for users to understand.
While these proposals sit outside our direct remit,
we support them as part of a thoughtful, joined-up
programme of reform that must involve the Ministry of
Justice, HMCTS, the ECB, and other key stakeholders.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 38
CREDIT MANAGEMENT
Ultimately, reform needs to be about more than just
systems and structures; it’s about delivering a justice
system that works for everyone. That means efficiency,
but also fairness, clarity, and accessibility. Enforcement
isn’t about punishment; it’s about ensuring that
people can access the remedies they’re entitled to
and that those remedies are delivered in a way that’s
proportionate and respectful.
We believe the CJC report has laid a strong
foundation. The HCEOA and its members stand ready
to support delivery of this reform agenda. We are not
just implementers – we are stakeholders, partners,
and experts. And we’re committed to working with
government and regulators to build an enforcement
system for the future that delivers better outcomes for
all.
Author: Alan J. Smith is Chair of the High Court
Enforcement Officers Association (HCEOA).
THIS IS NOT ABOUT
PUSHING OUT
COUNTY COURT
BAILIFFS – IT’S
ABOUT RELIEVING
PRESSURE ON
THE SYSTEM AND
PROVIDING MORE
EFFECTIVE SERVICE
FOR EVERYONE.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 39
HR MATTERS
RAIN
OR SHINE
The challenges of speculating, age, and umbrella companies.
BY GARETH EDWARDS
IN Gourlay v West Dunbartonshire Council,
the claimant, a corporate health and safety
officer, was dismissed for gross misconduct.
He successfully brought claims for unfair
dismissal, disability discrimination, and
victimisation, with the tribunal accepting
that the respondent’s discriminatory
treatment left him permanently unfit for work due to
severe depression.
At the remedy stage, the tribunal calculated the
claimant’s past and future wage loss and pension loss.
However, it then reduced the award by 80%, based on
two key assumptions:
That the claimant’s employment would have ended
by 2017, either through a breakdown in working
relationships or a mutual agreement to leave; and that
the claimant might have taken ill-health retirement
due to pre-existing conditions (multiple sclerosis and
Type 2 diabetes), regardless of his depressive illness.
The claimant appealed, arguing that the tribunal’s
compensation reduction was legally flawed. The EAT
upheld his appeal and found that the tribunal made
errors in how it assessed financial loss.
The purpose of compensation in discrimination
claims is to restore the claimant to the position
they would have been in had the employer not acted
unlawfully. The tribunal wrongly assumed that the
claimant would have been lawfully dismissed within
a few years. However, because the discriminatory
dismissal caused his inability to work, the tribunal
needed to consider whether a lawful dismissal would
have had the same effect. There was no evidence to
suggest that it would have.
The tribunal also wrongly speculated that the
claimant might have retired early due to other health
conditions. The EAT found that this assumption was
made without any medical evidence and contradicted
the expert psychiatric opinion that the claimant’s
condition was caused entirely by the respondent’s
unlawful treatment. As a result, the EAT overturned
the 80% reduction and remitted the compensation
assessment to a new tribunal.
Compulsory retirement
In Scott v Walker Morris LLP, the claimant was an
equity partner at Walker Morris LLP; his relationship
with the firm was governed by a members' agreement.
The claimant was due to retire on 30 April 2020, in
accordance with the retirement policy for partners in
the members’ agreement. The policy allowed partners
to apply for an extension to their membership if
they wished to continue working beyond the age of
60. A partner could apply for an extension of up to
three years if they could demonstrate an ‘exceptional
contribution’ to the firm. After the first extension,
a further request could be made at age 63 to extend
membership until the age of 65.
Under the Equality Act 2010, age is a protected
characteristic. Direct age discrimination occurs when
an individual is treated less favourably because of their
age and the treatment cannot be justified. Justification
must be both legitimate and proportionate and
supported by evidence.
A PARTNER COULD
APPLY FOR AN
EXTENSION OF UP
TO THREE YEARS
IF THEY COULD
DEMONSTRATE
AN ‘EXCEPTIONAL
CONTRIBUTION’
TO THE FIRM.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 40
CREDIT MANAGEMENT
In this case, the respondent admitted that the
termination of the claimant's membership due to his
age constituted less favourable treatment. However, it
argued that its actions were justified as a proportionate
means of achieving legitimate business objectives, such
as protecting the firm’s interests and ensuring intergenerational
fairness among its partners.
The tribunal focused on whether the justification was
proportionate. The respondent argued the policy helped
maintain a cohesive and collegiate atmosphere among
partners, avoiding potentially difficult and degrading
performance management of older partners. Second,
it suggested that the policy supported workforce and
succession planning, ensuring that there were enough
partners to maintain the business’s profitability and
stability.
However, the tribunal found that while these aims were
legitimate, the firm's approach was not an appropriate
or reasonably necessary means of achieving them. The
tribunal noted that the respondent couldn’t show that
poor performance at partner level was an issue, or
that the policy contributed to workforce or succession
planning.
Additionally, the tribunal found that less discriminatory
alternatives could have been implemented. The tribunal
concluded that while the firm's aims were valid, its
approach was not justified as a proportionate means of
achieving them.
Umbrella companies
HM Treasury published the Government’s response
to its consultation on tackling non-compliance with
employment rights and tax obligations by umbrella
companies.
The response confirms that the Employment Rights
Bill will be amended to define umbrella companies,
introduce a regulatory framework, and bring them
within the remit of the Employment Agency Standards
Inspectorate.
THE REGULATION
OF UMBRELLA
COMPANIES WILL
ALIGN THEM WITH
THE CONDUCT OF
EMPLOYMENT
AGENCIES AND
EMPLOYMENT
BUSINESSES
REGULATIONS 2003
The Government will define umbrella companies
with two key indicators – a company that employs
individuals with the purpose of supplying them to a
hirer, and an entity that manages payment for services
performed by individuals supplied to a hirer.
The regulation of umbrella companies will align them
with the Conduct of Employment Agencies and
Employment Businesses Regulations 2003, ensuring
consistency with existing rules governing employment
agencies and businesses. A statutory consultation will
be required before implementing any amendments to
the regulations.
Author: Gareth Edwards is a partner in the employment
team at VWV.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 41
CAREERS
IN REAL-LIFE
How to make industry events worth your while.
BY NATASCHA WHITEHEAD FCICM
PICTURE this: you’ve come across
an event on your LinkedIn feed
and it sounds like an interesting
opportunity, so you register to
attend. You go along with all the
right intentions, grab a free coffee
and croissant, listen in to the
panellists, take a mental note of a few relevant pointers
and make a swift exit. The trouble is you arguably
can’t tap into the long-lasting value of industry events
just by simply going along – a more proactive
approach will undoubtedly pay off in the long run.
Here’s how to get the best out of events, before,
during and after attendance, to ultimately advance
your career.
Before
A little bit of prep work prior to the event goes a long
way. It’s a good idea to carry out some surface level
research about the organiser, the main topic or debate
and if there are any panellists, so you know what
you’re heading into. You could come up with a couple
of questions that you’d like to ask, so you can address
what you want to get out of the discussion to expand
your knowledge and support your role.
It goes without saying but for an in-person event,
be sure to map out your journey in advance to avoid
being late or arriving in a fluster. Similarly, if the event
is online, seek a quiet room to help you focus and
consider muting your emails or other communication
channels to limit distractions and fully immerse
yourself in the event.
During
Attending events, and hearing relevant presentations
from industry leaders, is one of the most effective
ways to stay up to speed with all the pressing topics
that are affecting the word of credit. To make the
most out of the valuable insights up for grabs, listen
actively and write notes about anything that strikes
you as interesting and useful.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 42
CREDIT MANAGEMENT
instance. Attendees of credit circles often share legal
information on debtors and problematic customers,
which in turn will help you to know your customers
better and reduce credit risk to your business.
This goes both ways, as you can also give something back
to the industry and offer someone else a helping hand,
as they progress their career and navigate challenges
that they are facing within their own business. Be open
to offer your expertise, advice and recommendations.
After
Take a moment to reflect on the event including what
went well, what your key takeaways were, who you met
and how what you learnt this time around can benefit
you when it comes to future events.
Consider what your next steps are for continuing to
strengthen your network. You could reach out to a
key contact you made and arrange to meet for a coffee
to continue your conversation. Make sure you keep a
record of who you networked with so you can return
to this list should future opportunities arise to connect
again and support one another. Remember it’s not
all work and no play – networking and socialising go
hand in hand and it is amazing how quickly industry
contacts become friends!
Push yourself out of your comfort zone and strike up
a conversation with a stranger. A lot of people attend
events on their own, and are also feeling apprehensive,
so be brave and make the first move by asking
something light such as “how was your journey” or
“how’s business for you at the moment?”.
Take the prime opportunity to grow your network
by building new connections and sharing contact
details. People working in credit have their own web of
contacts across the sector and often refer each other for
new opportunities or projects, and attending industry
events will raise your own profile within the industry,
so you can utilise this vast network of professionals.
Networking at events enables you to get
recommendations that you may otherwise miss out on,
as your credit peers might be able to tell you about a
brilliant company that can automate your allocations
process, a new credit referencing agency or a business
that can implement AI into your O2C process for
A great way to raise your profile internally within your
own business is to bring information and new ideas
that you have acquired back into your organisation,
to support your team in their day-to-day roles and
to boost productivity across your company. You can
also have suggestions at the ready in terms of how to
implement your key learns into your role specifically
that your colleagues can learn from to support progress
and innovation. Talking to other credit professionals
about the challenges they’ve overcome and successes
they’ve achieved will hopefully give you a new
perspective and fresh ideas that you can take back to
your business. These could be anything from how they
incentivise their workforce or how they have built a
stronger relationship with sales.
Final thoughts
There is so much to be gained from industry events
by dedicating time beforehand to prep, clarifying
what you need from the event to enhance your career,
arriving with the right attitude, being approachable
and personable, actively engaging with the insights
available, offering your own and putting in some work
post-event to keep the ball rolling.
Author: Natascha Whitehead is Senior Business Director
at Hays specialising in Credit Management.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 43
LITIGATION
FUNDING
LINES
Litigation funding: to regulate or not to regulate?
BY JONATHAN RUSH AND BARNEY STANNARD
THE litigation funding market in
England and Wales has grown
rapidly in recent years under a
largely self-regulated regime but
change may be on the horizon
in the aftermath of the Supreme
Court's decision in PACCAR,
which prompted renewed public discussion about the
funding industry and the extent to which it facilitates
access to justice.
The Government has indicated that it will consider
any recommendations made by the Civil Justice
Council (CJC), which recently released its interim
report on the subject, and which is currently running
a public consultation on approaches to regulation.
Once the CJC's final report and recommendations
are published, the Government has indicated it will
consider further regulation. Meanwhile, the European
Parliament has urged the EU to impose more extensive
regulation of litigation funding across all EU member
states. Should the UK follow suit?
Third-party litigation funding (TPF) is an arrangement
whereby a third-party (typically a commercial funder)
agrees to cover all or part of the legal costs of a party
to legal proceedings, in return for a fee if the party is
successful. TPF is provided on a non-recourse basis,
which means that there will be no return for the
funder in the event the funded party does not win the
case. The terms of these arrangements will generally
be set out in a litigation funding agreement (LFA).
Current Regulation
Since its introduction, TPF in England and Wales
has been subject only to voluntary self-regulation,
with no formal regulatory oversight. Protections
for parties involved in funded claims are afforded
primarily by a combination of funders joining
the voluntary regulatory body (the Association of
Litigation Funders – the ALF) and by the courts
applying common law rules.
Historically, TPF was not permitted in England and
Wales because of the rule against champerty, which
is concerned with controlling the circumstances
in which a person with no direct interest in the
proceedings may exert control over them, for example,
by paying some of the costs of the litigation in return
for a share of the proceeds. The policy concern here is
that the funder's interest in its own profit may have a
distorting effect on the conduct of the litigation.
However, in 2002, the Court of Appeal ruled that
only funding arrangements that 'undermine the
ends of justice' should be subject to the rule against
champerty. This has meant that, until very recently,
it was rare for funding arrangements to be challenged
in the courts.
Voluntary Regulation
A voluntary system of regulation does exist for
litigation funders in England and Wales, for those
which are members of the ALF. The majority of large,
established litigation funders in England and Wales
are members of the ALF and must comply with its
code of conduct which provides rules on capital
adequacy of funders and outlines sanctions for
upheld complaints against funders. The sanctions are
relatively minor given the scale and value of funded
litigation, including expulsion from the ALF, the
imposition of a fine of up to £500 and the payment of
all or any of the costs of determining the complaint.
In PACCAR, the Supreme Court reversed the
findings of the lower courts and held that litigation
funding agreements pursuant to which the funder
is entitled to a percentage of any damages recovered
are ‘damages-based agreements’ (DBAs) within the
meaning of section 58AA of the Courts and Legal
Services Act 1990. Consequently, such agreements
are (i) unenforceable unless they comply with the
Damages-Based Agreements Regulations 2013; and
(ii) impermissible in opt-out collective proceedings
pursuant to section 47C(8) of the Competition Act
1998.
PACCAR led to a widespread revision of funding
arrangements, a large proportion of which overnight
became unenforceable. The attempts to fix such
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 44
CREDIT MANAGEMENT
If affected, the recommendations made in the Voss
Report would have a significant impact on the
litigation funding market in Europe by introducing
award caps, independent regulators, and disclosure
obligations.
It should be noted that the European Commission is
under no obligation to propose any corresponding
legislation in response to the report, but the
recommendations paint a clear picture of the potential
direction of travel towards increased regulation of
litigation funding in the EU.
Reversing PACCAR
The former Conservative Government had intended
to reverse the PACCAR decision by implementing the
Litigation Funding Agreements (Enforceability) Bill.
However, the Bill did not make it through the washup
prior to the general election and the incoming
Labour Government has confirmed that it has no
immediate plans to reintroduce it. The Government
has indicated that it will await the outcome of the
CJC's review of the current regulatory landscape for
litigation funding before considering any legislation.
agreements in place for various significant claims
in the High Court and the Competition Appeal
Tribunal (CAT) have been or are in the process of
being challenged by defendants.
The effect of PACCAR has been felt particularly
acutely in the collective actions regime in the CAT.
This is because all successful applicants for Collective
Proceedings Orders have satisfied the requirement
that they have access to sufficient resources to enable
them to act fairly and adequately in the interests of
the class (and are therefore a suitable person to be
authorised as a class representative) by having an LFA
in place. Accordingly, there are multiple appeals on
funding issues outstanding (some of which are to be
heard together), impeding the progress of cases in the
CAT.
New Proposals
Currently, there is no formal EU-wide system of
regulation of litigation funders but in September
2022, the European Parliament voted in favour of a
report entitled Recommendations to the Commission
on responsible private funding of litigation. Known
as the Voss Report, it seeks to introduce a regulatory
framework for TPF across EU member states and
makes recommendations to the Commission to
implement a directive which will establish ‘common
minimum standards’ for TPF in the EU.
So is there a case for greater regulation in the UK?
Beyond the continuing commercial uncertainty for
litigation funders and funded claimants as the courts
grapple with the impact of PACCAR, and concrete
legislative proposals from the new Government are
yet to materialise, the Post Office Horizon case has
also increased public scrutiny of the TPF sector.
Of the £58m settlement award made in that case
(which was funded by Therium) only £12m was
distributed between over 550 claimants (equating to,
on average, just over £21,000 per claimant – although
some may have been entitled to a higher share than
others) with the remaining sum being claimed by
the funders. This outcome has been widely criticised
as unjust in circumstances in which many of the
claimants had lost their livelihoods and contributed
to the Government introducing a compensation
scheme to ‘top-up’ the settlement amounts received
by claimants.
On the other hand, Sir Alan Bates, one of the former
sub-postmasters and first claimant in the proceedings,
has publicly stated that without litigation funding,
the sub-postmasters could not have brought their
case and exposed the wrongdoing of the Post Office.
As such, the Post Office litigation demonstrates both
why litigation funding is needed and some of the
drawbacks to pursuing funded claims.
Potential recommendations
Following the decision in PACCAR, the Lord
Chancellor commissioned the CJC to conduct a
review of the litigation funding sector. The CJC
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 45
continues on next page >
LITIGATION
interim report, published in October 2024, precedes a
consultation process which will result in a final report
with recommendations.
The interim report contains a survey of the different
approaches taken in other jurisdictions with respect
to TPF. This survey includes an overview of the EU's
approach and makes reference to the Voss Report
but makes no assessment of the suitability of the
Voss proposals for regulation of litigation funding in
England and Wales. While the final recommendations
from the CJC's review are awaited, the suggestion that
the CJC might be evaluating proposals for regulation
similar to those made in the Voss Report (as described
above) will likely raise concern in some quarters, given
the mixed response that report received.
But do we need more regulation of litigation funders?
According to the European Parliament, the answer is
a clear ‘yes’ – hence the regulatory regime proposed by
the Voss report – but only the European Commission
has the power to initiate legislation, and its response
is still awaited. In the interim, the proposals set out
in the Voss report have been subject to criticism
from the funding industry due to a perceived lack of
evidence-based analysis in the report.
The CJC is yet to set out any proposals to reform
the approach to litigation funders in the courts of
England and Wales but there are suggestions that it
will be far less interventionist than the EU regulatory
regime proposed by the Voss report.
Andrew Lenon KC, who sits as a chairman of the
CAT indicated that it seems ‘unlikely at this stage that
the CJC will recommend particularly prescriptive
regulation of funding’ during a keynote speech given
at the Global Class Actions Symposium in November
2024. It is also worth noting that the European Law
Institute (ELI) published a report in October 2024
(Principles Governing the Third Party Funding of
Litigation) which set out principles intended to
constitute a blueprint for light-touch regulation of the
litigation funding market. The report acknowledges
the Voss Report's advocacy for increased regulation
but notes that ‘prescriptive regulation’ is ‘is only
appropriate where there is an identifiable problem or
market failure’.
To regulate or not
Depending on the outcome of the CJC review, and
in light of the criticism that the Voss report has
received from the funding industry, the Government
may be disinclined to impose further regulation on
the market for litigation funding in England and
Wales. Yet, the key risks outlined by the Voss Report
apply equally to funded cases in England and Wales
– in particular that funders will maximise their own
returns at the expense of those expecting to benefit
from litigation. Indeed, these risks are acknowledged
in the CJC's interim report.
As for funders themselves, it might be thought that
they would have little interest in being regulated
more than they are at present. However, many of the
claims which litigation funders are often called upon
to back involve large numbers of individual claimants
with limited resources. Currently, the market for
those types of claims is somewhat constrained by the
limited availability of procedural mechanisms for
bringing collective actions on an opt-out (rather than
an opt-in) basis; in practice, it is difficult to bring such
claims except in the context of certain competition
law damages actions.
So far, the Government has resisted calls to expand the
competition collective actions regime to other areas,
usually citing concerns that this could encourage
a US-style litigation culture. It may be that greater
regulation of litigation funders, particularly greater
transparency about their role and perhaps greater
powers of oversight for the courts, would help to allay
some of these concerns – which could in turn pave
the way for an extension of the competition collective
actions regime to other areas.
Proportionate approach
The EU's tendency to take a more prescriptive
approach to regulation is reflected in some of the
recommendations of the Voss report, notably the
requirement for what is effectively a licensing regime
for funders and the 40% award cap. The UK has often
expressed a preference for what it regards as a more
proportionate and market-led approach, as reflected
in its better regulation principles. In particular,
the danger of a one-size-fits-all cap on the share of
proceeds that funders can seek is that it may result
in funders becoming unwilling to back litigation on
that basis. This might mean the UK would not feel
the need for a licensing regime but could instead
increase the ability of the courts to scrutinise funding
arrangements on a case-by-case basis. Such an
approach would be more flexible with the potential
to be varied according to the circumstances of each
case – and would only involve intervention where the
court judged it to be necessary.
If the UK does take a lighter touch approach to
regulation, any such regulatory divergence between
the UK and the EU may affect the relative allocations
of funders and the availability of funding between the
jurisdictions.
Author: Jonathan Rush is a Knowledge Counsel, and
Barney Stannard is a Partner, at Travers Smith.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 46
BRANCH NEWS
A REVITALISING
FOCUS
The CICM Yorkshire Ridings Branch Re-launch.
CREDIT management professionals
from across Yorkshire came together
in April for a dynamic and forward-looking
event marking the
relaunch of the CICM Yorkshire
Ridings Branch, hosted in partnership
with Hays Recruitment.
Held in Leeds, the event welcomed a packed audience
for a morning of insightful sessions, networking,
and strategic discussions on the future of credit
management. With a revitalised focus on supporting
credit professionals across North, East, and West
Yorkshire, the branch reaffirms its commitment to
community, training, and excellence in these changing
times.
The event opened with a warm welcome from Claire
McManus, Director at Hays, and Ian Torkington
MCICM, Branch Chair and Head of Client Services at
Cashroom. Setting the tone, they highlighted the vital
role credit management plays in today’s uncertain
economy and the importance of re-establishing a
strong regional network.
Dan Walker MCICM, Co-Founder of AI for Business,
delivered an engaging keynote on AI in Credit &
Collections. Dan explored how artificial intelligence
is revolutionising the sector, with practical advice
on deployment strategies, ROI measurement, and
managing organisational change when integrating AI
into credit teams.
Following Dan, Luke Sculthorp FCICM, Head of
Strategic Relationships at CICM, presented essential
updates on CICM's 2025 initiatives. His talk focused
on the expanding CICM apprenticeship programmes,
the value of CICMQ accreditation for organisations
aiming to benchmark best practice, and the Institute’s
renewed efforts to support career development,
governance, and talent retention.
Rounding off the speaker sessions, Claire McManus
from Hays provided a comprehensive overview of
current credit recruitment trends, highlighting key
labour market challenges, skills shortages, the impact
of new government legislation, and strategies for both
hiring and retaining top talent in the credit sector.
Key themes and takeaways:
• AI is here to stay: Credit teams need to start
integrating AI thoughtfully to boost efficiency, reduce
risk, and maintain competitive advantage
• Talent development is critical: With rising
employment costs and increased competition for
skilled professionals, businesses must invest in
training, apprenticeships, and flexible working
environments
• Market pressures require adaptation: From
demographic shifts to wage inflation and societal
demands for sustainability and diversity, credit
management must evolve to meet new challenges.
The Yorkshire Ridings committee announced plans
for further events later in 2025 and invited feedback
from attendees to shape future agendas around realworld
needs. They encouraged all professionals —
CICM members and non-members alike — to get
involved, strengthen networks, and help raise the
profile of credit management in the region
The event concluded with a lively Q&A session and
an opportunity for delegates to network over lunch,
setting the foundation for a renewed and energised
CICM presence across Yorkshire.
Author: Luke Sculthorp FCICM.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 47
Looking for
your next
career move?
Credit Controller
North Manchester, £29k
With markets across the UK and Europe, due to business growth,
our client is seeking an experienced Credit Controller to join
their credit team. Reporting to the Credit Manager you will work
as part of a credit team and be tasked with managing your own
B2B European ledger, chasing overdue monies via Portal & Email,
allocating cash and customer query resolution. Proficiency in
using SAP is preferred. Ref: 29425MB
Contact Joanna Taylor-Coburn on 0161 926 8605
or joanna.taylor-coburn@hays.com
Credit Controller
Sutton/Epsom, up to £35k + bonus
Reporting to the Credit Control Supervisor, and working as part
of a friendly team, you will be responsible for managing circa 300
live accounts with a debtor ledger of approx £8m per month. The
varied duties within this role include ensuring timely collections
of payments, processing incoming funds, resolving account
queries, and overseeing debt recovery process. Ref: 4639637
Contact Mark Ordona on 07565 800574
or email mark.ordona@hays.com
Credit Team Leader
Birmingham, £34k - £38k
We are supporting a charitable organisation based in
Birmingham that is recruiting for a Credit Team Leader
to join them on a permanent basis. You will manage a
small but growing team of three and will remain hands-on,
managing your own ledger of up to 600 accounts.
This position offers hybrid working, with two days a week
in the office. Ref: 4655167
Contact Henry Brook on 0333 010 7517
or email henry.brook@hays.com
Credit Controller (Insurance)
Norwich Norfolk, up to £35k
As an experienced Insurance Credit Controller, you will work
closely with brokers and underwriters to ensure the collection
of all monies. The portfolio will have at least 25 key customers,
and you will manage approximately 1800 premiums from major
businesses based across Europe. This role is based in Central
Norwich, Norfolk, and you must have previous experience of the
insurance markets to be considered. Ref: 4678539
Contact Andy Jarman on 01603 760141
or email andy.jarman@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
Senior Accounts Receivable Assistant
London, up to £40k
This is an exciting opportunity to join a dynamic retail company,
managing a ledger of EMEA clients. You will oversee the
accounts receivable processes, ensuring timely collections and
handling multicurrency transactions. You will collaborate with
internal teams to resolve payment discrepancies and prepare
financial reports. Experience of working with multi-currencies is
essential. Ref: 4639645
Contact Katie Bohun on 0203 465 0020
or email katie.bohun@hays.com
Legal Biller
London, £40k - £46k
A top UK law firm, based in the City of London is looking for a
bright legal biller to join their successful and welcoming finance
team. This opportunity is well suited for an individual with 2-5
years of legal billing experience and offers brilliant progression,
supported by an experienced team of billers. Ref: 4659334
Contact Lara Santis on 0333 010 2474
or email lara.santis@hays.com
Discover new
opportunities today
© Copyright Hays plc 2025. All rights are reserved. CM-00885
BEREAVEMENT
DIGITAL
NOTIFICATIONS
Guidance welcome but digital notifications should be mandated.
BY PHIL HICKSON
IN our recent report Probate or Pro-wait – how to
make the hardest part of life easier, we recounted a
story of how a bereaved widow had to contact
more than 20 individual organisations to
inform them that her husband had died. We
also reported that nearly three in four (72%)
of 2,000 UK adults surveyed agreed that every
bank and utility company should have a specific death
notification service similar to the ‘Tell Us Once’ service
provided by the Government.
We are delighted, therefore, to learn that the Financial
Conduct Authority (FCA) has published new guidance
on how banks should treat customers in vulnerable
circumstances – including bereavement – following a
review of current practices (published 12 April, 2025).
‘Good’ firms, it identified, had clear customer policies and
procedures with regard to vulnerability, which often set out
the expected timeframe for staff to process registration of
bereavement and Power of Attorney (PoA) cases.
The FCA also identified where things needed to improve.
In some cases, there was clear evidence of poor practice
or lack of awareness of internal policies exacerbating the
distress for customers and their representatives when they
did not get the support they needed. Staff did not always
acknowledge that customers were noticeably upset, even
though failing to recognise and respond sensitively can have
a direct impact on the customer’s confidence in engaging
with financial services.
There are several recommendations as to how firms might
consider adapting their bereavement customer journeys
to help ensure they are as straightforward and flexible as
possible. It is also encouraging to know that most firms that
the FCA engaged with have dedicated bereavement teams.
What especially stuck out for me, however, was the
common issue shared across multiple banks and financial
services providers: customers (particularly in bereavement
processes) had to repeat information when speaking
to different staff members, or had their cases delayed
or dropped altogether because they had been ‘lost’ in
the firm’s systems, risking further distress and upset.
The FCA also highlighted how fragmented customer
relationship management (CRM) systems across business
lines could make it more difficult to keep track of cases
and process them efficiently. ‘We encourage firms to focus
on ensuring customer journeys are fit for purpose across
legal entities, to reduce the risk that consumers do not get
their needs met or must repeat information unnecessarily,’
it says.
It is especially interesting because it taps into our opinion –
borne out by our research – that the lack of any universally
agreed, digitally-based process for death notifications
within the private sector is contributing to a more stressful
bereavement experience.
As owners of the bereavement notification services
NotifyNOW and Settld, we have previously called on the
FCA and the Government to go much further in their
plans to require firms to accept digital death verification.
We have also long believed that third-party providers
should be mandated to have a dedicated bereavement
team and minimum Key Performance Indicators
in how the bereaved are handled. It seems that the
FCA agrees.
Every bank, utility company and service provider – and not
just those regulated by the FCA – should have a consistent
death notification service and much better signposting
is needed to steer consumers to the help available in
explaining how the process works.
The guidance from the FCA is a welcome first step – but it
needs to go further. We should harness the momentum that
is now being generated and accelerate the appointment of
a Bereavement ‘Tsar’ within the Government to champion
the better treatment of consumers managing a death. We
need a powerful voice with the authority to hold firms
to account. Guidance is the first stage, but what’s really
needed is mandatory action.
For a copy of our report, Probate or Pro-wait – how to make
the hardest part of life easier, Go to the FCA website.
Author: Phil Hickson is SVP, global Partnerships at The Estate
Registry.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 50
CREDIT MANAGEMENT
WE HAVE ALSO LONG BELIEVED
THAT THIRD-PARTY PROVIDERS
SHOULD BE MANDATED TO HAVE A
DEDICATED BEREAVEMENT TEAM
AND MINIMUM KEY PERFORMANCE
INDICATORS (KPIS) IN HOW THE
BEREAVED ARE HANDLED.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 51
INSOLVENCY
THE WALLS
OF JERICHO
Is the construction industry on the brink
or are statistics misleading?
BY PHILIP KING FCICM
SINCE 2021, the construction sector
has accounted for almost one in five
of all corporate insolvencies. The
percentage has ranged between the
lowest of 15.1% (November 2024) and
the highest of 20.4% (February 2022).
The percentage for all corporate
insolvencies across the 10-year period from 2015 to
2024 was 17.7%, or one in every 5.65. Sadly, there’s little
to suggest the number’s going to change any time
soon.
The latest Government Office for National Statistics
(ONS) trend figures over three months reveal an
industry in stagnation, recording no net growth
overall. The S&P Global/CIPS UK Construction PMI
in March remained in contraction, with new orders
declining for the third month in a row, and just 40%
of firms expecting output to rise in the coming 12
months. The more recent Flash Composite PMI for
April slid to a 29-month low of 48.2.
At the time of writing, many are predicting a cut in
the Bank of England interest rate from 4.5% to 4.25%
in May. While this can be beneficial for small firms
that rely on borrowing, it can also lead to companies
taking on debt that can hide underlying financial
problems. It’s a time to be watchful and wary.
Fixed-price challenges
Firms in the construction sector struggle when fixedprice
contracts prevent them from passing on rising
costs. Also, cashflow suffers from hikes in material
costs, project delays, and supply chain disruption.
Costs are increasing, both through National
Insurance Contributions and a rise in the minimum
wage. Inflation is still an issue, as is the uncertainty
arising from tariffs being imposed by the US. As such,
it’s reasonable to assume the rate of insolvencies is
unlikely to diminish across the rest of 2025.
Brendan Clarkson of PKF Littlejohn Advisory
agrees. He observes that Compulsory Liquidations in
February 2025 reached their highest level in 10 years
as a result of HMRC and local authorities stepping up
their activity and showing less forbearance than had
hitherto been the case. The total in February 2025 was
49% higher than in February 2024.
Creditors are also becoming more proactive in
pursuing outstanding debts and are increasingly
resorting to legal action. His firm is seeing a rise in
enquiries for restructuring and insolvency support,
with directors seeking specialised advice on managing
their business finances amidst escalating costs. Small
businesses, in particular, find it challenging to pass on
additional costs to customers while still wanting to
remain competitive.
So what are things like on the ground? I’ve talked to
some Top Service clients and members to get their
views on the year so far.
Reduction in overdues
There’s a consensus that collections have performed
well; relatively few bad debts have been experienced
and, generally, they are of low value. A reduction in
overdues is also being seen and, where customers are
struggling, more are taking a proactive approach to
arranging payment plans. This is a positive sign of a
willingness and desire to honour debts rather than
walk away and leave the supplier unpaid.
There’s less common consensus on the commercial
front, however. Some have seen sales start to pick up
and are feeling positive, opening more new accounts
than ever, while others say trade has not increased
to the levels they’d anticipated and that it’s a
battleground to win business. One member observed
that things are eerily good and they’re waiting for a
shock!
I also asked what their main current ‘pain-points’
were and identified a variety of issues. Taking
decisions without adequate information was high
on the list. There are a number of reasons for this:
companies filing minimum information or having no
requirement to file because they are so new, and the
resulting unavailability of credit insurance leading to
trading at their own risk.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 52
CREDIT MANAGEMENT
Requests for payment plans, and customers seeking
increased credit limits, also featured. A particular
difficulty was granting more credit when customers
were unwilling to provide additional information, such
as management accounts or draft statutory accounts.
Handling the commercial pressure to offer more credit
in these circumstances was also a factor causing pain.
Account analysis
One member highlighted the difficulty of reaching
any form of conclusion from analysing year-on-year
accounts. Everybody has had a tough year, and the
majority of accounts show negative movement. Success
lies in determining which had a tough year and are
weathering the storm, and which had a tough year and
are on their last legs.
There was common recognition of increasing instances
of fraud, and the need for greater vigilance and better
avoidance systems. One single instance can have a
devastating impact on a company’s survival, so it’s an
area that needs constant focus.
In general, and particularly in regard to collections
performance, it seems that experience at the coal face
is better than suggested by the more general insolvency
statistics and predictions. I see a couple of possible
reasons for this. Firstly, the impact of increased
employment costs, US tariffs, and rising employment
costs have yet to be fully felt, and it may be a matter
of timing. Secondly, it’s likely that these Top Service
members have best practice credit management
processes, get real-time shared payment experience,
and have effective systems in place. They’re more adept
at spotting risks and warning signs, at being proactive
in managing and minimising overdue debts, and – as I
said in my last contribution to this magazine – at being
willing to give and receive information about their
customers which puts them on the front-foot.
Author: Philip King FCICM is a non-executive
director at Top Service Ltd.
A REDUCTION IN OVERDUES IS
ALSO BEING SEEN AND, WHERE
CUSTOMERS ARE STRUGGLING,
MORE ARE TAKING A PROACTIVE
APPROACH TO ARRANGING
PAYMENT PLANS.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 53
International Trade
Monthly round-up of the latest stories
in global trade by Andrea Kirkby.
MADE IN BRITAIN’S
EXPORT SUPPORT IN 2025
*
*
A Government agency, Made in Britain,
aims to support members to sell more of
what they make overseas, as well as in
the UK. It has a number of programmes
to help it do so.
There’s an International Trade
Newsletter, published quarterly that
features curated export news, events,
and updates. Also available is an
International Trade programme which
offers online sessions that cover key
markets identified in a Made in Britain
export survey as holding the best
options for UK manufacturers. Each
session features presentations and
Q&A by Made in Britain companies plus
insights from Department for Business
and Trade experts and the organisation’s
Export Academy.
There have been sessions on
Latin America with discussions on
the Comprehensive and Progressive
Agreement for Trans-Pacific Partnership’s
impact after it comes into force; and
Europe with detail on how to export
to European markets. Later in 2025
sessions are planned on the USA and
Canada (July), and the Middle East
(September) including the UAE and Saudi
Arabia.
Beyond this is help with navigating
regulatory challenges in international
markets, market-entry assistance,
and overseas partnerships. There are
other resources to tap into such as free
Government resources for exporters, a
UK Export Academy with free training,
funding from UK Export Finance,
Keep an eye on the Made in Britain
website at https://tinyurl.com/2n3kv25w.
China as a business opportunity?
THERE’S an interesting bit of editorial
in ExportExperts Magazine which asks,
‘can the UK optimise China as its best
business opportunity?’
It considers that China is now the only
functioning major economy in the world
and looks set to be so for some time.
But this is not the only factor that
puts it in the position of being the UK’s
best international sales prospect as
there’s also a great appreciation of
British brands, culture and heritage
and the respect for the way business is
conducted. Beyond that there’s Chinese
enthusiasm for Brexit combined with the
handicap rival US businesses face due to
Trump’s hostility to China.
However, it’s not all plain sailing as
there’s the ‘British Disease’ – the lack
of awareness and ability to localise to
indigenous culture and business practice
– a point noted by Domenica Di Lieto,
CEO of Chinese marketing consultancy,
Emerging Communications.
She reckons that misunderstanding
Chinese culture leads to
underperformance and failure and has
resulted in highly damaging consumer
boycotts. She gives the example of
Dolce and Gabanna’s flawed decision
to use a Chinese model struggling to
eat Italian food with chopsticks as the
theme for a promotional video – it was
said to comprehensively wipe-out longterm
sales in what was by far its biggest
market.
Di Lieto says that there are only two
ways forward – ‘create a cross-cultural
team or appoint a specialist third party to
create and oversee strategy and tactics
while at the same time training to build
management self-sufficiency.’
You have been warned.
JEREMY CLARKSON HAS
AMBITIONS WITH BEER
BUSINESS Matters has reported on plans
that motoring journalist, farmer and now
brewer, Jeremy Clarkson has for his beer
brand, Hawkstone.
As the publication said, what began as
a local collaboration using barley from
his Diddly Squat farm is now Britain’s
fastest-growing privately owned brewery
— and it’s just getting started.
Launched in 2021, Hawkstone is
brewed in partnership with the Cotswold
Brewing Company. The brand, co-owned
by Clarkson and entrepreneur Johnny
Hornby, had revenues of £7.8m in the
year to March 2025. It’s now planning to
go international.
The original idea was to combine
Clarkson’s profile with British farming
and brewing. Hawkstone uses barley
grown on Clarkson’s farm and has
positioned itself as a premium product.
The brewery has since expanded its
range to include low-alcohol options.
Business Matters said that Clarkson
envisions Hawkstone in 200,000 pubs,
from the Pacific Northwest to Brisbane.
Though tongue-in-cheek, the ambition
is serious. It added that Elon Musk was
recently seen sipping Hawkstone on a
yacht in France.
SMALL BUSINESSES AND THE
WINDSOR FRAMEWORK
THE FSB in Northern Ireland has
launched a survey to assess the
impact of the Windsor Framework on
small businesses across the UK. The
framework is an agreement aimed at
easing trade between Northern Ireland
and the rest of the UK after Brexit.
The survey seeks to gather feedback
from businesses of various sizes,
sectors, and across the regions, and
provide crucial insights into how the
framework is affecting them. The
findings, we are told, will play a key role
in FSB's efforts to advocate for policies
that improve the trading environment for
SMEs in the UK.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 54
THE FT ON TRUMP’S TARIFFS
IT may be old news, but we cannot ignore
the elephant in the room – President
Trump’s tariffs on global US imports that
the FT says will dent the UK Government’s
fragile growth ambitions and hit key
manufacturing sectors.
The UK’s 10% levy – while less than the
20% faced by the EU and higher elsewhere
– will clearly weaken demand and disrupt
supply chains at a time when businesses
are already facing rising costs.
The paper quoted Shevaun Haviland,
Director-General of the British Chambers
of Commerce, who said that orders will
drop, prices will rise, and global economic
demand will be weaker as a result.
Similarly, Emma Rowland, trade policy
advisor at the Institute of Directors, told
the FT that the tariffs would be a blow to
British businesses that would force many
HIGH LOW TREND
to reassess the viability of the US as both a
market and a supply-chain hub.
The UK sells more services than goods
to the US and export sectors were left
non-plussed by the imposition of tariffs.
Farmers will be concerned as the US is
the UK’s second-largest destination for
British food exports after the EU; car
manufacturers will be too as one in six
[high end] cars goes to the US.
On the positive side, the FT noted that
UK manufacturing just became more
competitive than many other countries,
especially when compared with a number
of low-cost countries.
Tariffs can be lifted at any time and there
is some hope that either Trump is forced to
change course, or a deal can be negotiated.
Regardless, if he doesn’t a one-man-made
global recession is on the cards.
Trade bodies call for EU-UK
standards mutual recognition
GBP/EUR 1.18993 1.16041 UP
GBP/USD 1.34433 131433 FLAT
GBP/CHF 1.11852 1.07685 UP
GBP/AUD 2.10072 2.04906 DOWN
GBP/CAD 1.86251 1.8304 UP UP
GBP/JPY 196.369 187.586 UP UP
THE Chartered Institute of Export &
International Trade has written that several
trade organisations on both sides of the
English Channel have called for a change in
conformity regulation could boost UK and
European economic growth and remove
trading barriers.
According to the organisations – the
institute as well as LightingEurope,
Make UK, and the Confederation of
Swedish Enterprise, such an agreement
would increase stability for regulatory
environments; avoid duplicating
conformity assessments for both British
and European businesses who want to
trade in both markets; and provide greater
availability of conformity assessment
bodies.
The call for change reckons that such
an agreement could be achieved either
as part of a ‘mini-deal’ or alongside other
industry-focused measures. The call notes
that the UK Accreditation Service (UKAS)
is assessed to the same standard as EU
equivalents making it easier to achieve an
agreement.
Notably, the UK-EU Trade and
Cooperation Agreement which governs
trade relations between the UK and the
EU, is also due to be reviewed next year.
For the latest
exchange rates visit
www.currenciesdirect.com
or call 020 7874 9400
Currency Exchange Rates
This data was taken on 16th May
and refers to the month previous
to/leading
up to 15th May 2025.
CREDIT MANAGEMENT
THERE’S MONEY IN WIND
UK Export Finance is to provide a
£184m credit guarantee to support the
construction of the 495 MW Fengmiao
1 offshore windfarm in Taiwan,
securing £55m in manufacturing and
service export contracts for British
suppliers.
As the story runs, Cadeler – based
in East Anglia – is to supply an
installation vessel together with crew,
sea-fastening services and crane
operators.
The deal is part of a wider $3.7bn
financing package by Copenhagen
Infrastructure Partners which involves
export credit agencies from Denmark,
Netherlands, Poland, Belgium, and
Taiwan.
Located off the west-coast of
Taichung City, the offshore wind site is
due to be completed in 2027.
GOOD NEWS FOR NI?
A report on the BBC, citing Nobel prize
winning economist Paul Krugmanm,
reckons that following the imposition
of US trade tariffs, EU firms will try to
export goods via Northern Ireland in
an attempt to get a reduced tariff rate
when exporting to the US.
Northern Ireland is part of the UK but
also has an open trade border with the
Republic of Ireland, which is in the EU.
Krugman said that ‘probably a lot of
EU goods trans-ship through Northern
Ireland to get the lower tariff rate.’
However, goods cannot just be
exported via a lower tariff country to
get a lower tariff. Instead, they need to
undergo ‘substantial transformation’
in the lower tariff country, which usually
means some form of processing.
This could bode well for Northern
Ireland in terms of work for ports and
firms involved in ‘processing’.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 55
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
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 56
EXCLUSIVE PAYMENT TRENDS
ON THE ROCKS
Late payments on the up across the board.
BY ROB HOWARD
WHEREAS last
month’s Payment
Trends provided
plenty of optimism,
the latest late
payment statistics
are a stark contrast,
with the vast majority of regions and sectors across the
UK and Ireland heading in the wrong direction. The
average Days Beyond Terms (DBT) across UK regions
and sectors increased by 0.3 and 0.5 days respectively.
In Ireland, average DBT rose by 1.2 and 1.5 days
respectively. Across the four provinces of Ireland, the
average figure increased by 2.9 days.
Sector Spotlight
More than half (13) of the 22 UK sectors saw increases
to their DBT. But before diving into those, it’s worth
noting that nine sectors did make improvements. Of
those, the standout performer without a doubt, is the
Manufacturing sector, which moves off the bottom of
the standings after cutting its DBT by 8.1 days taking
its overall tally to 11.1 days. At the other end of the
scale, the Financial and Insurance sector, which was
among the top performing sectors, saw an increase of
7.7 days taking its overall DBT to 12.4 days and making
it the second worst performing sector. The Water and
Waste sector has taken over as the worst performing,
with a rise of 5.8 days taking its overall DBT to 13.0
days.
The sector outlook in Ireland is similar, with 12 of the
19 sectors going backwards. Its Water and Waste sector
continues to suffer and move further adrift at the
bottom of the standings, with a further increase of 11.8
days taking its overall DBT to a massive 72.8 days. For
context, and to highlight the size of the gap, the second
worst performing sector – Agriculture, Forestry and
Fishing (+8.4 days), now has an overall DBT of 18.2
days. Elsewhere, the Education (+7.5 days) and Mining
and Quarrying (+6.2 days) sectors are also on the slide.
Looking at the positives, the IT and Comms sector
is on the up, and moves into the top five performing
sectors, with a reduction of 6.0 days taking its overall
DBT to 5.0 days.
Regional Spotlight
On the surface, the UK regional figures probably look
worse than they are. Some seven of the 11 regions saw
increases to DBT, but the majority of these were fairly
minor. For instance, London and the West Midlands
saw the biggest increases, both experiencing a rise of
2.4 days to their DBT, followed by Wales (+1.6 days)
and Northern Ireland (+1.4 days). Meanwhile, the
North West (+0.9 days), South West (+0.7 days) and
South East (+0.4 days) all saw increases of less than one
day.
The picture across the Irish counties is more of a
mixed bag. Some 16 of the 26 counties saw increases
and some of these are significant, but equally, there are
some significant improvements among the 10 counties
moving in the right direction. Of those making strides,
Wexford and Waterford made the biggest gains,
reducing their DBT by 9.2 and 8.9 days respectively.
Meanwhile, a reduction of 4.7 days puts Offaly into
second place in the standings with an overall DBT of
3.9 days. However, a number of counties are in freefall.
A significant rise of 13.2 days means Cavan is now the
second worst performing county with an overall DBT
of 22.7 days, while Monaghan (+10.6 days) and Galway
(+9.3 days) also saw large increases to their DBT.
Three of the four Irish provinces saw increases to DBT,
while Leinster (-0.4 days) made a small improvement.
Ulster saw the biggest jump, and is now the worst
performing province, with an increase of 7.3 days
taking its overall DBT to 14.7 days.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 57
*
STATISTICS
Data supplied by the Creditsafe Group
Top Five Prompter Payers
Region (UK) 25 Apr Changes from Mar 2025
SOUTH WEST 6.8 0.7
SCOTLAND 7.8 -0.2
SOUTH EAST 8.2 0.4
EAST MIDLANDS 8.5 -1.7
WALES 9.2 1.6
Bottom Five Poorest Payers
Region (UK) 25 Apr Changes from Mar 2025
EAST ANGLIA 12.7 -4.6
NORTH WEST 10.5 0.9
NORTHERN IRELAND 10.4 1.4
WEST MIDLANDS 10.0 2.4
YORKSHIRE AND HUMBERSIDE 9.9 0
Getting worse
Financial and Insurance 7.7
Water & Waste 5.8
International Bodies 5.1
Energy Supply 4.7
Business Admin & Support 2.1
IT and Comms 1.8
Construction 1.5
Other Service 1.5
Real Estate 0.9
Entertainment 0.4
Top Five Prompter Payers
Sector (UK) 25 Apr Changes from Mar 2025
BUSINESS FROM HOME 5.0 0.1
EDUCATION 5.2 -0.8
INTERNATIONAL BODIES 5.7 5
ENTERTAINMENT 6.3 0.4
AGRICULTURE, FORESTRY & FISHING 6.4 0.3
Bottom Five Poorest Payers
Sector (UK) 25 Apr Changes from Mar 2025
WATER & WASTE 13.0 5.8
IT AND COMMS 12.8 1.8
FINANCIAL AND INSURANCE 12.4 7.7
BUSINESS ADMIN & SUPPORT 11.5 2.1
OTHER SERVICE 11.5 1.5
Agriculture, Forestry and Fishing 0.3
Public Administration 0.2
Business from Home 0.1
Getting better
Manufacturing -8.1
Dormant -3.9
Professional and Scientific -3.2
Hospitality -1.8
Wholesale and retail trade; repair of
motor vehicles and motorcycles -1.6
Education -0.8
Mining and Quarrying -0.7
SCOTLAND
-0.2 DBT
Health & Social -0.5
Transportation and Storage -0.3
NORTHERN
IRELAND
1.4 DBT
SOUTH
WEST
0.7 DBT
WALES
1.6 DBT
NORTH
WEST
0.9 DBT
WEST
MIDLANDS
2.4 DBT
YORKSHIRE &
HUMBERSIDE
0 DBT
EAST
MIDLANDS
-1.7 DBT
LONDON
2.4 DBT
SOUTH
EAST
0.4 DBT
EAST
ANGLIA
-4.6 DBT
Region
Getting Better – Getting Worse
-4.6
-1.7
-0.2
2.4
2.4
1.6
1.4
0.9
0.7
0.4
0.0
East Anglia
East Midlands
Scotland
London
West Midlands
Wales
Northern Ireland
North West
South West
South East
Yorkshire and Humberside
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 58
EXCLUSIVE PAYMENT TRENDS
Getting worse
CONNAUGHT
3.8 DBT
LEITRIM
-2.8 DBT
ULSTER
7.3 DBT
CAVAN
13.2 DBT
Water & Waste 11.8
Agriculture, Forestry and Fishing 8.4
Education 7.5
MUNSTER
1.1 DBT
CLARE
-1.2 DBT
LEINSTER
-0.4 DBT
CARLOW
-2.8 DBT
WATERFORD
-8.9 DBT
LOUTH
-4.1 DBT
DUBLIN
2.6 DBT
Mining and Quarrying 6.2
Hospitality 3.4
Energy Supply 3.0
Public Administration 2.7
Professional and Scientific 1.7
Health & Social 0.7
Financial and Insurance 0.5
Top Five Prompter Payers – Ireland
Region 25 Apr Changes from Mar 2025
LEITRIM 3.0 -2.8
OFFALY 3.9 -4.7
LONGFORD 5.3 -3.1
CLARE 6.0 -1.2
WICKLOW 6.3 2
Bottom Five Poorest Payers – Ireland
Region 25 Apr Changes from Mar 2025
CARLOW 35.2 -2.8
CAVAN 22.7 13.2
LOUTH 18.8 -4.1
WATERFORD 18.2 -8.9
GALWAY 17.3 9.3
Top Four Prompter Payers – Irish Provinces
Region 25 Apr Changes from Mar 2025
MUNSTER 7.9 1.1
LEINSTER 11.1 -0.4
CONNACHT 11.9 3.8
ULSTER 14.7 7.3
Other Service 0.3
Real Estate 0.2
Manufacturing 0.1
Getting better
IT and Comms -6
Transportation and Storage -3.6
Entertainment -1.8
Construction -1.6
Business Admin & Support -1.4
Wholesale and retail trade; repair of
motor vehicles and motorcycles -0.3
Real Estate -0.2
Top Five Prompter Payers – Ireland
Sector 25 Apr Changes from Mar 2025
INTERNATIONAL BODIES 0.0 0
ENTERTAINMENT 2.2 -1.8
OTHER SERVICE 4.3 0.3
IT AND COMMS 5.0 -6
MINING AND QUARRYING 6.2 6.2
Nothing changed
International Bodies 0
Bottom Five Poorest Payers – Ireland
Sector 25 Apr Changes from Mar 2025
WATER & WASTE 72.8 11.8
AGRICULTURE, FORESTRY & FISHING 18.2 8.4
BUSINESS ADMIN & SUPPORT 13.2 -1.4
TRANSPORTATION AND STORAGE 12.3 -3.6
REAL ESTATE 11.0 -0.2
Brave | Curious | Resilient / www.cicm.com / June 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.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 60
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 are the CICM Enforcement Business
of the Year. Recognised for our professional, client-focused,
and approachable service, our expert team has enforced over
100,000 Writs, recovering over £105m for clients and claimants
since the end of the pandemic. Our commitment to excellence
is reflected in our client satisfaction survey, where 100% of
respondents confirmed we meet or exceed expectations as a
High Court enforcement supplier, with many highlighting our
superior collection performance over industry competitors. We
work closely with legal professionals, businesses, and individuals
to provide ethical, effective, and fully compliant enforcement
solutions. Combining experience with innovation, we ensure the
best possible outcomes while upholding the highest standards of
professionalism, integrity, and service excellence.
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.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 61
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
E: creditorservices@menzies.co.uk
W: www.menzies.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 Giuseppe Parla,
Licensed Insolvency Practitioner, at:
E: gparla@menzies.co.uk / tel:+44 3309 129828
FIS
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.
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.
W: www.fisglobal.com.
FIS is a financial technology company providing solutions to
financial institutions, businesses and developers. We unlock
financial technology that underpins the world’s financial system.
Our people are dedicated to advancing the way the world pays,
banks and invests, by helping our clients confidently run, grow
and protect their businesses. Our expertise comes from decades
of experience helping financial institutions and businesses adapt
to meet the needs of their customers by harnessing the power that
comes when reliability meets innovation in financial technology.
Headquartered in Jacksonville, Florida, FIS is a member of the
Fortune 500® and the Standard & Poor’s 500® Index. To learn
more, visit www.FISglobal.com. Follow FIS on Facebook, LinkedIn
and X (@FISglobal).
Thornbury Collection Services Ltd
T: 01443 224407
E: Info@thornburycollections.co.uk
W: www.thornburycollections.co.uk
We are a CICM Award winning company, founded in 2002
Our head office is located in Cardiff, helping clients throughout
the UK and internationally, specialising in commercial B2B debt.
Working with clients of all sizes, from one-man bands to
multinational companies, offering a full turn key service with end
to end support, the perfect piece of the credit jigsaw. Offering
terms and conditions, reviewing, enhancing and drafting credit
processes. Credit control support packages , awareness and
training sessions, recovering debts and dispute resolution.
Facilitation of court work, enforcement and the collect out of full
debtor books.Small enough to care Big enough to win.
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.
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.
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.
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 62
View our digital version online at www.cicm.com
Log on to the Members’ area, and click on the tab
labelled ‘Credit Management magazine’
Just another great reason to be a member
Credit Management is distributed to the entire UK and international
CICM membership, as well as additional subscribers
Brave | Curious | Resilient
www.cicm.com | +44 (0)1780 722900 | editorial@cicm.com
Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 63