Olivia Kearney
Plenitude Insights
FraudThat means demonstrating capability across:
➡️Customer onboarding➡️Authentication
➡️Transaction monitoring
➡️Customer communication
To help with this, we created a Fraud Readiness Playbook, a practical guide that translates Article 149 into actionable priorities tailored to your size, complexity, and risk profile.
At Plenitude, we have experience supporting global and UAE based FS firms (and regulators) in environments where scrutiny is high and timeframes are tight. Based on that, we’re seeing most organisations focus on four pressure points:
➡️Clear accountability: Defined ownership, escalation, and oversight across 1st and 2nd lines➡️Control effectiveness: Are your fraud controls keeping pace with evolving threats across channels/products?
➡️Incident response: Strengthening notification, documentation, and customer handling
➡️Regulatory readiness: Ensuring MI, audit trails, and evidence can stand up to inspection
The transition period runs until 16 September 2026, but firms are expected to complete assessments and embed capabilities well before then.
The playbook is built to be:
➡️A self-assessment tool➡️A planning framework
➡️A prep resource for regulatory engagement
