NETS Case – Breaking down gaps into actions


In the ever-changing payments sector, there are always things happening around the companies within it. Nets is no exception. Operating in X countries, with more than 70 legal entities under their umbrella, Nets creates value for their stakeholders by delivering payments and digital services that are used by thousands of merchants, hundreds of financial institutions, thousands of corporates and millions of consumers across across Europe, and that benefit communities and society as a whole. As the payments sector is faced with increased regulation and digital complexity, staying compliant in all countries they operate in is proving to be an increasingly daunting task. Together with FCG, Nets have now audited all their subsidiaries in their AMLD4 and PSD2 compliance, and have now developed a tool to stay on top of their activities.

The Challenge

Regulation regarding AML and payments often derives from a European level, but are then locally interpreted and enforced. When a company like Nets operates in a variety of European countries, keeping track of local law and requirements can be a tricky ordeal, and can be helped by using data to get a sense of where they are at with their work to ensure compliance. In 2018, Nets saw the need to improve their overview of what degree of compliance is in place, and what activities were needed. They wanted to do a full audit of all their 70+ subsidiaries in what is commonly referred to as a GAP analysis.

 Citat Nets om utmaningen, gärna något om hur svårt det är att vara ett så pass stort bolag och ha koll på lokal regulation

The Solution

Together with FCG, a full GAP analysis was conducted in the winter of 2019/2020, encompassing AMLD4 and PSD2. Both pieces of regulation also had to be adjusted with local requirements, so that the audit would be applicable to the various countries in which Nets operates. A number of potential improvements were found with some of the NETS subsidiaries around Europe, and a list of recommendations was delivered from FCG. With the GAP analysis as a foundation, FCG then helped Nets in developing a digital tool to get a proper overview of their governance, as well as actively working with the great number of activities needed to stay compliant (delivered in the spring of 2020). We call the tool the Gap Action Dashboard , which enables leadership to follow up on governance activities, as well as report progress to internal stakeholders.

Among the results of the work, the following was found (gärna bilder till listan):

  • A 300+ page full report on the GAP analysis, with recommendations to each of the entities audited.
  • A Board presentation of the results, paired with an Executive Summary of the results
  • An application overview
  • A documentation overview
  • The Gap Action Dashboard (anonymized version with “excerpt of results” ?)

“Citat Nets om lösningen, gärna något om vilken inverkan en så stor GAP har givit dem en bättre förståelse för AMLD och PSD2, samt hur Action Dashboard hjälper dem att hålla reda på sina aktiviteter och prioriteringar.”

The Results

Are there any quantifiable results? 

Citat Nets med effektmål av resultaten från GAP och Gap Action Dashboard

Kan vi ta exempel från s.33 i ex. summ. om vilka gapen var. Innan hade man svårt att få översikt, nu hade man ett mycket tydligare sätt att identifiera, prioritera, och agera på actions.


“Citat Nets om resultaten, gärna om samarbetet med FCG och vår expertis