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Deep Fathom

Deep Fathom has since 2001 been delivering digitally native compliance audits to reveal insightful and actionable areas for improvement in regulated organisations. These next-generation audit reports provide (leading as well as lagging) data-driven insights into the culture, training, risk, compliance, ESG, and other important areas of your business.

The digital-first nature of the audit platform reduces the time, distraction and cost to your team to complete audit requirements. The reports automatically generate clear and actionable results with your Green Swan compliance team conducting policy reviews as part of the 'blended' internal audit process if required. The blended audit combination ensures that the human input is not overlooked and that focused remediation actions are concentrated in the right areas - avoiding distraction and stress across your wider team.


Your progress and improvements are easily evidenced ahead of any external audit. Your team will feel more confident in their external audit preparation having supporting data that the business is being run in the right way.

Green Swan Compliance and Deep Fathom have fine-tuned these reports based on our extensive experience with the challenges that UK based EMIs, Agents, and Distributors face in the current regulatory and commercial environment. 


These internal audits have been designed to a specific audit scope for:

- EMI Agents and Distributors wishing to prepare efficiently and effectively for an external audit (or in a situation where an improvement in control has been suggested or required) by the EMI license holder and

- by EMI principals with Agents and Distributors that wish to supervise their own Agents and Distributors more effectively and effectively.


Green Swan and Deep Fathom have worked collaboratively to create this digital Regulatory Audits as a Service (RAaaS) tuned to the needs of UK EMIs their, Agents and Distributors. RAaaS is typically a fraction of the cost associated with a traditional manual audit. RAaaS can be used as a 'health check' or 'current state business review or in an internal audit mode in preparation for your external audit as well as providing supporting data and tracking for your external audit team. 


Regulatory Consultancies 

Industry Bodies

We are strong supporters of UK Finance and CIFAS and the role that they play in the maturing FinTech industry ecosystem. Please note that whilst we provide implementation support to organisations making the transition to CIFAS they are a 'members only' body for regulated institutions.

Technology Stack

We use enterprise-grade technology to support our authentication to our IT system, data security and data protection. ISO27001 is and remains an important standard for our technology supplier vetting process. Efficient digital data-driven processes are important to us not only to fight financial crime but also to deliver genuine insight into what is often a complex situation.  


Our customers and various regulatory organisations often have a need to know and understanding of some of the technologies that we use to provide services. The list below represents an indication of our enterprise grade technology stack and is provided for informational purposes only. We are customers (not partners) of many of the technology providers below:


Artificial Intelligence (AI)

AI will undoubtedly have an enormous transformative effect on the world, and the way virtually every organsation operates in the next decade and beyond, possibly more so than the cumulative effects of the www and mobile phones - only time will tell. What is for sure (and for those of us that have spent many years in technology) is that Moore's Law is proving remarkably resilient and with it everything that it empowers! 


The perpetrators of large-scale organised financial crime are almost always 'tech savvy and seriously 'tech enabled'. They are invariably first movers and almost always  fast movers when it comes to implementing new technology and their use of AI also. 

It is essential that financial organisations and the international collective financial crime community use this technology to tackle organised financial crime on a level playing field. We never make automated financial crime decisions on AI indicators alone. 

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