Brexit Response Programme

Complex Client Migration

Brexit Response Programme – Complex Client Migration
21/08/2019 MHC
of in scope migrations achieved
client meetings completed across UK, North America and Europe
of compliant clients' accounts activated (1809 in scope).


In response to the UK’s decision in June 2016 to leave the European Union (EU) our client, a global Tier 1 Bank, undertook a Brexit Response Programme to migrate their main European payments connectivity, via TARGET2 & EURO1, from the UK to Germany to protect their customers from cross-border fees levied against them from EU Banks for receiving non-compliant payments according to Payment Services Directive 2 (PSD2) rules which state that for a Euro SEPA payment to be PSD2 compliant, both the remitting bank and beneficiary bank should to be located within the EU. Once the UK leaves the EU, currently scheduled for 31st October 2019, a SEPA payment sent from the UK will be PSD2 non-compliant as one leg of the payment will be outside the EU and therefore potentially liable for additional cross-border payment transfer fees outside of the normal cost of transfer.

The main client sectors the changes will impact is the Financial Institutions (FIs) and the Non-Bank Financial Institutions (NBFIs) and in particular the Payment Service Providers (PSPs) who send large volumes of international payments on their clients’ behalf.

MHC were engaged to assist our client by providing experienced Client Migration Managers to migrate the NBFI/FI client sectors Euro payment systems, products and payment volumes to Frankfurt to eliminate the risk of non-compliant SEPA payments attracting additional charges which would negatively impact the NBFI/FI client sectors value proposition to their clients.


The MHC migration team followed the subsequent approach in migrating the Bank’s Clients’ payment systems, products and volumes:


+ Established and reviewed impacted clients, accounts, systems, products and services

+ Agreed actions required, including roles, responsibilities and timescales for completion

+ Assisted with communication plan and documentation provided to clients throughout the migration life-cycle


+ Drafted and produced Project Initiation Document and Migration Project Plan for each client detailing: Scope, Timelines, Impacted Entities, Accounts and Products

+ New Entity Requirements (for the client to continue to utilise passporting rights across  the EU post Brexit)

+ Lessons learnt logs from previous MHC supported migration projects were utilised at an early stage to mitigate risk and ensure a smooth transition


+ Designed and implemented quality assurance and control methodology and systems

+ Chaired daily incidents call with Germany Operations Team documenting any outstanding issues, impacts, issue owners and resolutions

+ Successfully troubleshooting bank/client issues in a timely manner making sure clients received an enhanced experience and successful migration

+ Ensured the banks NBFI/FI client sector(s) are at business readiness for the UK leaving the EU on 31st October 2019

Closure and Review

+ Reviewed the migration project with the client before formally agreeing project closure

+ Drafted and agreed audit processes and procedures with programme directors

+ Carried out full project audit ensuring all relevant documents were securely stored and saved for future auditing purposes

+ Documented any client issues throughout the project as well as post project closure follow-ups

+ Handed over clients to their normal ‘Business as Usual’ Global Relationship and Servicing Teams



All qualifying clients were successfully migrated, and system tested within the allotted project timeframes.

The MHC Team received glowing reviews externally from the bank’s clients as well internally from Global Relationship Directors.