Small Wins Add Up
# The Project I Almost Killed, And What Five Years of Hindsight Taught Me About Momentum I still remember sitting across from my programme manager in month three, watching her make a genuinely reasonable case for why we should stop. She was not wrong on the facts: the project had no visible wins, the team was tired, and the internal stakeholders who had commissioned the work had already moved on to three other priorities. We were rebuilding a regulatory reporting framework for a business unit that had been quietly non-compliant for years, not dramatically, not dangerously, but consistently enough that someone senior had eventually noticed and handed me the problem, the kind of problem that arrives without fanfare and leaves without applause. She laid out the argument for pausing clearly, professionally, with a slide deck that made stopping look almost responsible. I nearly said yes, not because I believed it was the right call, but because I was tired too, and tired people find well-reasoned arguments more persuasive than they should. The Situation I was working on this project in 2019. The business unit had been operating on a patchwork of manual processes and institutional memory for the better part of a decade. Nobody had deliberately built a broken system: it had simply grown in the way most broken systems grow, one pragmatic workaround at a time, until the workarounds became the system. My job was to replace it with something that would actually hold under regulatory scrutiny. The challenge was that progress, in this kind of work, does not look like progress for a long time. I was not building features, I was excavating. Every week we found another process that existed only inside someone’s head, another data feed that connected to a spreadsheet no one had updated since 2016, another exception that had been handled manually so long it had stopped being seen as an exception at all. To anyone watching from outside the room, we appeared to be standing still. My programme manager’s case for pausing was rational: a pause, she argued, would give us time to regroup, re-engage stakeholders, and come back with a cleaner plan. The logic was sound, and that is precisely why it was dangerous. In complex rebuilds, “coming back with a cleaner plan” is usually a polite way of describing the moment a team loses its nerve and never quite recovers it. I had seen it before, the pause that becomes a pivot that becomes a quiet cancellation eighteen months later. What I said instead was this: we are not pausing, but we are going to do one thing differently. Every week, I would identify one thing that is measurably better than it was seven days ago, not a milestone, not a formal deliverable, just one thing, documented, visible, shared with the team. It sounds almost embarrassingly simple, that is, I suppose, the point. What the Next Five Years Taught Me The first insight is that momentum is not a feeling, it is a record. What changed from month three onwards was not the pace of work, it was the existence of evidence. Every Friday, there was something concrete to point to: a data feed validated, a manual step eliminated, a process documented for the first time. Individually, each item was unremarkable, collectively, they became the proof that the project was alive. And that proof did something I had not fully anticipated, it made the team stop measuring progress against the original plan and start measuring it against last week, that is a much more honest comparison, and a far more sustainable one. I have since watched organisations spend enormous energy on formal programme governance, traffic-light reports, steering committees, milestone reviews, while neglecting the simpler practice of recording what actually improved. The bureaucracy of progress is not the same as progress itself. The second insight is that stopping teaches something you cannot easily unteach. Had we paused in month three, the framework would probably have resumed eventually, projects like this rarely die entirely, they get restarted, rebranded, handed to someone new. But the team would have carried a piece of learning that I think is genuinely corrosive in professional environments: that when progress is hard to see, stopping is the appropriate response. That lesson travels, it shows up in the next project, and the one after that, as a lowered threshold for retreat. The damage of an unnecessary pause is rarely visible in the project itself, it is visible in the people. The third insight is the one that took longest to articulate clearly: consistency is not the slow path. Most senior people I know, and I include myself in this, with some embarrassment, are instinctively drawn to the bold intervention, the restructure, the strategic pivot, the announcement that signals decisive leadership. These things have their place, but I have watched more value created by sustained, unglamorous consistency than by any single bold move, and I have watched more value destroyed by the instinct to reach for drama when patience was actually what the situation required. The regulatory framework that is now running across three regions was not born from a brilliant insight in month three, it was built one documented improvement at a time, over two years, by a team that had decided to stay in the room. What This Means in Practice If I am leading a complex programme right now, a technology rebuild, a regulatory change, a cultural shift, and progress is invisible, the question worth asking is not whether to pause, it is whether I have created the conditions for small progress to be seen at all. Most organisations are reasonably good at celebrating the launch and catastrophically bad at recognising the incremental work that makes launches possible. The team that ships quietly, week after week, without a milestone in sight, is doing the most important work in the building, they are also the most likely to be told to pause. I build the record, I show
Bright and Early: Leadership Insights from London
What 5:51am Taught Me That No Meeting Ever Could At 5:51am in London, the sky is genuinely undecided, not dark, not light, something in between that has not yet chosen a direction. I find that oddly reassuring. The city has not started demanding anything from me yet. The inbox is technically open but morally closed. The coffee in my hand is still hot enough to count. I used to treat this hour as a competitive advantage. Up before the market, ahead of the inbox, winning the day before it started, that kind of framing. The problem with that framing, I have since learned, is that it turns the one quiet hour I have into another form of performance. I am still running. I am just running earlier. That distinction matters more than I thought it did. The Situation That Corrected Me I was three months into a regulatory restructure that covered two jurisdictions simultaneously in early 2021. I will spare the details, partly for confidentiality and partly because the details were less interesting than the chaos they produced. What I can say is this: the number of stakeholders involved was significantly higher than the number of clear answers available. Everyone had a perspective. Everyone had a risk appetite, a reporting line, a political consideration. The meetings were long and the clarity was short. I was running on the assumption that volume equals progress. More sessions, more calls, more documentation. If I kept moving, I would eventually arrive somewhere useful. I did not. I circled. The moment I remember most clearly was a Tuesday morning in February. I was up before six, not out of discipline but because I had woken up at four with something unresolved and could not get back to sleep, which, if anyone is quietly selling this as a glamorous executive habit, I should know the origin story is usually just low-grade insomnia. I made coffee. I sat down. I had no agenda and nobody needed anything from me for at least another two hours. And in that space, without anyone asking me a question or handing me a problem to react to, the answer I had been looking for arrived. Not the whole answer. But the structural insight that had been obscured by the noise, the thing I had been unable to see because I had been too busy generating activity to allow any actual thinking. I decided to shift the restructure after that morning. Not because of a meeting. Because I had finally been quiet long enough to hear what I already knew. What That Morning Actually Demonstrated The first thing it demonstrated is that thinking and doing occupy different mental states, and most organisations are structurally committed to the second at the expense of the first. Calendars fill with rooms full of people producing outputs. The outputs are real. But the underlying thinking, the kind that questions whether those outputs are the right ones, has no scheduled slot. I do this thinking in margins. If I have no margins, it does not happen. The second thing it demonstrated is something I now believe fairly firmly after two decades across regulated industries: the quality of a decision is often inversely related to how many people were in the room when it was made. That is not an argument for isolation. It is an argument for protecting the phase of thinking that precedes the room. I should arrive at the meeting with a considered view, not form my view inside it. The meeting should test my thinking, not replace it. The third thing, and this is the one that took me longest to accept, is that stillness is not a reward. For years I treated quiet mornings as something I had earned by being productive the day before. If I had had a hard week, I deserved a slow Saturday morning. That framing is backwards. Stillness is not a reward for finishing the work. It is, structurally, where the useful work happens. It belongs at the front of the day, not as compensation at the end of it. That shift in sequencing changes everything about how I design my time. What This Means in Practice None of this is an argument for becoming a morning person. Some of the sharpest leaders I have worked with do their best thinking late at night, or on long walks, or in the car. The format is not the point. The point is that every leader I respect has some version of unstructured, undemanded time that they protect with the same seriousness they bring to a board meeting. They do not treat it as a luxury or a preference. They treat it as infrastructure. If I am currently running a team, or navigating something complex, or managing more stakeholders than I have clear answers for, my instinct will be to add more sessions, more touchpoints, more movement. I will resist that instinct occasionally. The breakthrough I am looking for is probably not hiding in the next meeting. It is more likely waiting in the next quiet morning I have not yet cancelled. Later Has People In It The sky over London has made its decision now. The city is loud and the inbox has opinions. Whatever I was going to think clearly about, I thought it an hour ago. The most useful thinking I do today will probably not happen between nine and five. It will happen in the margins I was disciplined enough to protect, not because I won the morning, but because I was finally still enough to hear myself. Later has people in it. Earlier, for a while, is just mine.
Night Owl Leadership: Why Not Everyone Peaks at 9am
I recall the moment it arrived at 11:47pm, the timestamp was right there in the commit log, precise and unapologetic. A complete architectural solution to a problem we had been circling in morning standups for three weeks. No preamble, no draft, no “just thinking out loud.” Ready for production review. My first reaction, I will admit, was not admiration. It was something closer to mild institutional irritation. I had spent eighteen months building a programme governance model that ran on calendar discipline and visibility. And here was one of our best architects producing the clearest thinking of the entire quarter at a time when I was firmly, unambiguously, asleep. That moment did not immediately feel like a lesson. It felt like a scheduling problem, which is precisely the kind of wrong answer that looks sensible at scale. The Situation I was deep into an enterprise data infrastructure overhaul – four regions, nineteen legacy systems, somewhere north of forty stakeholders depending on the week and the mood of the steering committee. The programme was running. Milestones were being met. By every external measure, I was in good shape. However, something kept slipping. Not deliverables – those were landing. It was the quality of the decisions inside the deliverables. The morning syncs felt sharp. The design reviews were engaged. And then, consistently, inexplicably, the decisions made in those rooms would begin to unravel within days. Not because the people were wrong. Because the thinking was incomplete. In late 2023, I pulled the contribution logs. I did this not to catch anyone out – the programme was not in crisis – but because I had a nagging suspicion that what I was measuring (attendance, responsiveness, meeting participation) had quietly drifted away from what I actually needed to track (thinking quality, architectural coherence, decision durability). What I found was uncomfortable in the specific way that useful findings tend to be. Two of my strongest architects – people whose judgement I trusted more than most governance frameworks I have ever read – were doing their clearest, most structurally complete thinking between nine and midnight. Not occasionally. Consistently. The contribution logs made it embarrassingly obvious in retrospect: the commits that unblocked other people’s work, the design notes that reoriented entire workstreams, the quiet corrections that prevented expensive rework. Almost all of it after hours. I had built a programme governance model around availability windows. The work was happening around them, not inside them. The thinking was occurring anyway – just invisibly, uncredited, at midnight, outside the architecture of the programme itself. What I Got Wrong The first thing I got wrong was conflating presence with production. I found comfort in a full calendar. It signaled momentum. It signaled alignment. It signaled that I was, at a minimum, in the same room as the people who were supposed to be solving the problem. What it did not signal – and this is the thing governance models consistently fail to encode – is when the actual thinking happens. I had optimised for observable effort and was quietly surprised when that turned out not to be the same thing as best effort. Chronotype is not a wellness concept. It is a cognitive variable. The research on this is not new – circadian rhythms, ultradian cycles, the neuroscience of alertness and decision-making under fatigue – but in enterprise transformation, it remains almost entirely absent from how I structure work. I talk about agility, about flow states, about psychological safety. And then I schedule the most cognitively demanding decisions at 9am on a Monday following a cross-regional steering committee. The second thing I got wrong was the word I kept using. When I began discussing how to respond to what I had found, the language in the room defaulted to flexibility and async policy. Both reasonable words. Both slightly beside the point. The word I kept avoiding – the one that actually described what my architects needed – was permission. Not a formal policy change. Not a new HR framework. The quiet organisational signal that your best thinking does not have to be witnessed to count. That is a harder thing to give than a flexible working policy, because it requires something institutions are structurally reluctant to offer: trust in the output over trust in the process. It means accepting that I will not always see the work happening. I will see what the work produces. The third thing I got wrong was treating this as an edge case. Two architects doing their best work at night sounds like a curiosity. An anecdote. A nice story for a team retrospective. What the contribution logs actually showed was a systemic misalignment between when my programme demanded cognitive energy and when my people had it to give. That is not an individual quirk. That is an organisational design problem. I restructured two workstreams around output quality, not presence. No midnight standups. No requirement to be online at any particular time. Clear deliverable expectations, clear quality standards, genuine latitude on when the work happened. Six weeks later: the same people, the same problems, measurably sharper decisions. Not marginally sharper. Structurally different. What This Means for Your Organisation Most high-performing organisations are already benefiting from their night-thinkers. They simply are not doing it intentionally, which means they are also not doing it efficiently, and they are almost certainly losing some of those people to organisations that make them feel less like they are working around the system. The competitive edge here is not in discovering that chronotype exists – your best people already know this about themselves. It is in building an operating model that makes their best thinking visible and valued, rather than something they contribute quietly, on their own time, hoping someone notices the timestamp. The organisations that figure this out will not just retain better people. They will extract the thinking those people were already doing anyway – just uncredited, in the margins, at 11:47pm – and bring it properly into
Small Steps, Big Progress: A Personal Leadership Story
The Particular Silence of a Programme That Has Learned to Perform Momentum I recall a specific kind of organisational stillness that does not announce itself, no alarm, no escalation call, no red flag on the RAG status. Just the quiet hum of meetings that end with actions nobody completes, decks that get refined rather than decided upon, and governance forums that produce minutes instead of movement. If you have ever sat inside this silence, you will recognise it immediately. If you have not yet encountered it, you will, and you will almost certainly mistake it for progress, because it has learned to dress that way. Stalled is not stopped. Stopped is visible. Stopped has a reason, a postmortem, a recovery plan. Stalled is insidious precisely because it looks, from a distance, like careful deliberation. The calendar is full. The stakeholders are engaged. The strategy deck has been updated to version fourteen. And yet the organisation has not moved, not really, in months. I spent the better part of a year inside exactly this situation, and the most uncomfortable thing I can tell you is that I did not see it clearly until much later. Not because I was not paying attention. Because the absence of crisis can be its own kind of blindfold. Eighteen Months In I was mid-programme, the dangerous middle, where the initial energy has long since dissipated and the end is still too far away to generate any fresh urgency, when I finally sat with the numbers and let them tell me something I had been avoiding. We were eighteen months into a cross-regional data transformation. The kind of programme that involves multiple geographies, legacy infrastructure that predates most of the team, regulatory considerations across jurisdictions, and the careful, painstaking work of getting organisations that have operated independently to agree on something as fundamental as how data should be classified. I had the governance forums. I had the steering committee. I had a transformation office and a methodology and a set of principles that had been workshopped, reviewed, socialised and signed off. What I did not have, when I sat down and looked at it honestly, was a single team that had completed a full migration and was operating differently as a result. I remember the specific meeting where this registered. Not a crisis point, there was no shouting, no failed deadline, no public moment of reckoning. Just a quiet conversation with two of my leads in which we tried to articulate what had actually changed in the last quarter, and found ourselves talking mainly about what we had prepared rather than what we had done. The decks were excellent. The readiness assessments were thorough. The roadmaps were beautifully structured. I had spent months building a perfect runway and had not yet taken off. The dry version of this is: I had optimised for planning and confused it with progress. The honest version is: I had let the programme learn to perform momentum, and I had not noticed quickly enough. What Actually Shifted The first insight sounds almost embarrassingly simple in retrospect, which is usually a sign that it is genuine. I stopped measuring against the destination and started measuring against last Thursday. Not last quarter. Not the original programme plan. Last week. The question I began asking in every team check-in was not “where are we relative to where we need to be?” but “what is different today that was not true seven days ago?” This change in reference point sounds minor. It is not. Measuring against a distant destination in a multi-year enterprise programme is a near-perfect mechanism for generating demoralisation, because the gap never closes fast enough to feel real. Measuring against last week creates a completely different relationship with forward motion, because even the smallest genuine movement becomes visible, and visible movement compounds. The second shift came from a single word, and I want to be precise about this because the word itself matters. The word was adjacent. Not “forward.” Not “progress”, a word so large it had become meaningless in our conversations. Adjacent: the next thing that is close enough to reach without requiring the organisation to believe again in the entirety of the vision. In practical terms, this meant I stopped trying to create conditions for the whole programme to move simultaneously and started identifying one data domain, one team, one geography where the conditions were already nearly right. I migrated that domain. I made it real, visible, and unremarkable, not a pilot, not an experiment, just the way that team now worked. Then I waited. Within a few weeks, the team running that domain had begun talking informally to the next team along. A regional lead asked to replicate the approach. The conversation changed from “why should we do this” to “how did you do that.” This is not a new insight about change management. But experiencing it at enterprise scale, after months of stalled momentum, makes it feel like a discovery every time. The third insight is the most counter-intuitive, and it is the one I am most confident about after everything I have seen in large institutions: small steps are not a compromise. They are not what I do when I cannot get organisational permission for the real approach. They are the only mechanism that actually works at enterprise scale, because enterprise scale means I cannot ask the entire organisation to believe in something it has not yet experienced. I can only ask a small part of it to take a step small enough to be genuinely reversible, and then let the evidence of that step do the work that no vision document ever could. What This Means for Your Programme If any of this is familiar, the full calendar, the unremarkable governance forums, the strategy deck on its fourteenth iteration, the question worth sitting with is not “what is wrong with our approach?” but “what is the one thing that could be different by next Thursday?”
Deep Focus as a Leadership Discipline
The Hedge Is the Trap I was running four workstreams across two geographies in late 2022. Each one had a legitimate case. I could have defended any of them in front of a board. There was a regulatory thread in one, a commercial opportunity in another, a partnership that had been eighteen months in the making, and a technology build that we had already sunk real money into. Individually, each made sense. Together, they made a very convincing picture of a senior executive who was across everything. By Thursday each week, I had touched all four and completed none. I told myself this was diligence. I told myself that senior work is inherently non-linear, that complexity requires parallel thinking, that running multiple streams simultaneously was evidence of capability, not avoidance. I was, as it turns out, an excellent storyteller, primarily to myself. Dubai, A Tuesday, A Question I Was Not Ready For. A colleague I have known for fifteen years sat across from me in Dubai. We were not in a formal review. We were between meetings, the kind of half-hour that exists because one meeting ran short and the next has not started. He did not ask what I was working on. He had seen the update decks. He already knew. He asked: “Which one would actually hurt to lose?” I answered in three seconds. Without pausing. One workstream. Immediately. No deliberation. He did not say anything for a moment. Then: “So what are the other three for?” I did not have a clean answer. What I had, sitting in that room, was the slow recognition that I had known for months, probably longer, which workstream actually mattered. The other three were not really about value. They were about optionality. They were insurance against being definitively, visibly, unambiguously wrong about the one that counted. The activity had felt like diligence. It was hedging dressed up as a work ethic. And I had been thorough enough about it that I had almost convinced myself otherwise. Three Things That Became Clear After That Conversation Focus is not a time management problem. Every article written about focus eventually slides into calendar hygiene, time-blocking, single-tasking, the Pomodoro technique. None of that is wrong, exactly, but it diagnoses the wrong condition. The reason most senior professionals scatter their attention is not that they have poor scheduling habits. It is that committing fully to one thing, before the outcome is certain, is genuinely uncomfortable. Spreading effort across four workstreams means that when something fails, you were not really betting on it. You were merely involved. Focus requires a different kind of exposure, the kind where, if the thing does not work, you cannot point to the three other things you were also doing. That discomfort is real. Managing it with busyness is entirely human. It is also, over time, professionally corrosive. The hedge is not neutral, it has a cost most people do not account for. When I was giving partial attention to four workstreams, I was not giving 25% to each. I was giving fragmented, context-switching, half-loaded attention to all of them, which meant none of them were getting the quality of thinking they needed. The one workstream that actually mattered was being shortchanged precisely because it mattered most. That is the cruel arithmetic of hedging: you protect yourself from the feeling of risk while simultaneously ensuring that your most important work is never fully resourced. The protection is real. The trade-off is invisible until it is not. Most senior people are not lazy. They are protecting themselves from being definitively wrong. I have seen this pattern in enough organisations now, across regulated industries, across geographies, across leadership levels, that I am comfortable saying it is structural rather than personal. The more visible your role, the more costly a clear, public failure feels. So the incentive is to stay in motion across many things rather than commit to one. This looks like productivity. It functions as risk mitigation. The organisations that break this pattern are the ones where leaders are genuinely supported when they commit and fail, not just when they succeed. That is a culture question, not an individual discipline question. Though waiting for the culture to change before you change is also a hedge. What This Means in Practice If you are leading a team or a function right now, the question worth asking is not “are we busy?” Almost certainly, yes. The question is whether the things consuming your week are the things that will matter when you look back in eighteen months. In my experience, the workstreams that get described as “important but not urgent” are often neither. They are placeholders, things that justify the feeling of motion without requiring the commitment that real priorities demand. Strategy fails when priorities are vague, which I wrote about separately when working through how we communicate decisions inside organisations. The same logic applies here: when everything is a priority, the word loses its operational meaning entirely. One of the clearest signs of leadership maturity I have seen, and this connects to the kind of continuous, embedded readiness we talk about in the context of operational resilience, is the ability to say “we are not doing that” and mean it, rather than “we will get to that” and not mean it. The work of focus is not scheduling. It is the act of committing to one thing before you know how it ends, and being willing to be wrong about it in public if it comes to that. The Close Most people are not scattered because they lack discipline. They are scattered because they have not yet decided that being wrong about one important thing is less costly than being irrelevant across many.
Momentum Through Small Progress
Momentum Is a Lie You Tell Yourself in Retrospect I was rebuilding in 2021, not the kind of rebuilding that makes for a clean narrative at a conference: I sat in my home office at 7am with cold coffee and genuinely wondered whether the version of myself I was trying to recover was actually worth recovering. The business pivot I had made the previous year had cost me more than I was prepared to admit publicly, or privately, for some time. The financial exposure was real but survivable. What surprised me, and I say this with the full awareness that I should have known better, was what the failure took from me that I had not put a value on: my confidence in my own judgment, time I will not get back, and a kind of professional identity I had worn for so long that I had mistaken it for my actual self. I had spent two decades advising organisations on transformation, risk strategy, and resilience. Apparently, the curriculum did not include a module on what to do when my own plan unravels on schedule. The Rule I Set Because I Had Nothing Else Somewhere in early 2021, I made a decision that felt embarrassingly small at the time. I gave myself one rule: do one visible thing each day, not a strategy review, not a restructuring plan, not the ambitious Q2 roadmap I kept drafting and abandoning. One thing: an email sent, a conversation completed, a document closed and filed, something that existed in the world after I did it, that had not existed before. I want to be honest about how that rule felt in practice. Some days, sending a single email was a genuine achievement. I would look at the rule, one visible thing, and think: this is a standard set for someone recovering from surgery, not someone who has run teams of several hundred people across multiple geographies. The bar was, objectively, on the floor. I kept the rule anyway, partly because I had nothing better, partly because the alternative was producing nothing, and I had enough experience with organisations in freefall to know that zero output days compound in the wrong direction just as fast as progress days compound in the right one. Ninety days in, I reviewed what I had produced, not to feel good about myself, I was not expecting to feel good about myself, but because I needed an honest read on whether the approach was working or whether I was simply managing a slow decline with better optics. What I found genuinely surprised me. The volume of work was not the surprise. What stopped me was that I could not draw a straight line from where I had been to where I was. The distance had appeared gradually enough that I had not registered it. Momentum, it turned out, does not announce itself. Three Things That Pivot Taught Me That No Strategy Course Ever Did Progress made quietly does not feel like progress. This is the trap most capable people fall into when they are behind. They have succeeded visibly before, they know what it feels like when things are working, the energy in the room, the metrics ticking up, the sense of forward motion that others can see. When none of that is present, my instinct is to conclude that nothing is working. That instinct is usually wrong. The compound effect of consistent small action is not a motivational phrase, it is arithmetic. But arithmetic does not feel like anything while it is happening. The ledger is invisible until I run the numbers. Waiting for readiness is a strategy for staying still. There is a version of professional discipline that looks like patience but is actually avoidance in good clothing. I have watched senior leaders wait for the right conditions, the right quarter, the right team configuration, and I have watched them wait themselves into irrelevance. In 2021, I was at risk of doing exactly that. The energy to do something significant does not precede action, it follows it. That sequencing matters. Getting it backwards is one of the most common and most expensive mistakes I have seen in executive careers, including my own. Consistency is a decision, not a character trait. I used to believe, and I hear this belief echoed constantly in leadership conversation, that some people are naturally consistent and some are not. That consistency is something you either have or you develop through habit. I do not think that is right anymore. What I experienced in that ninety-day period was not the emergence of a new habit, it was a daily decision, made again every morning, often against my own inclination. Some mornings the decision took five minutes of sitting at the desk and arguing with myself. Consistency is not a trait I possess, it is a choice I make when nothing feels worth doing. That distinction matters because traits are fixed and choices are not. What This Means If You Are Running Something Right Now If I lead an organisation, a team, or a professional practice that is currently behind where it should be, and most are, in some dimension, at any given time, my instinct is to wait for the moment when I can make a significant move. Restructure properly, relaunch with conviction, come back strong. I understand that instinct, I have acted on it, and I have watched others act on it, and I have seen what it produces. What it produces, mostly, is a longer period of stagnation with a more elaborate justification. The organisations I have seen recover fastest from genuine difficulty were not the ones that waited for the transformational moment. They were the ones that kept producing output, imperfect, incremental, sometimes undistinguished output, on the days when producing nothing would have been entirely forgivable. The compound effect is not selective, it does not care whether I am in a good quarter or a difficult one. It runs in
EU vs US: Navigating Regulatory Expectations
When the Regulator Calls First, You Have Already Lost I launched a fintech product in the US and the UK on the same day in 2017. It felt like a milestone. Two major markets, simultaneous entry, the kind of thing I put in an investor update with some pride. What I did not fully appreciate at the time was that I had not launched one product into two markets. I had launched two entirely different regulatory relationships, and I only understood that after one of them had already gone wrong. The US engagement started with a detailed inquiry. A user complaint had reached the regulator before my proactive risk framework had reached anyone. The product was live, customers were onboarding, and the first substantive conversation I had with a US regulator was reactive. I was explaining myself rather than introducing myself. The tone of that distinction matters more than most founders realise until they are sitting in it. The UK experience was almost the inverse. I had pre-application meetings, scenario testing, and a structured review of my risk framework before a single customer had touched the product. The FCA wanted to understand how I thought before they watched how I behaved. At the time, I found the process slow and occasionally bureaucratic. In hindsight, I would have paid for it. The Moment I Realised I Was Already Behind Here is the part I do not often tell. By the time I understood that my US launch was already out of compliance – not catastrophically, but materially – I had been operating for several weeks. The product had passed my internal review. It had passed legal. I had built a risk framework I was genuinely proud of. What I had not done was map my compliance assumptions against US-specific regulatory philosophy, because I had made the mistake of assuming that a well-built product with strong internal governance would translate cleanly across jurisdictions. It did not. The first user complaint was not about the product. It was about a data handling notice. A feature that no customer had meaningfully used – and that most of my team had forgotten was even in the product – had a data retention disclosure that did not meet state-level requirements in one US market. The regulator’s first question to me was not about my business model, my risk controls, or my financial standing. It was about my data retention policy for a feature my customers had ignored. I had spent months perfecting the user experience. The regulator’s opening question was about a disclosure buried in a settings page. There is a lesson in that irony that I have never fully stopped finding uncomfortable. Three Things I Now Understand That I Did Not Then The rules are not the philosophy. Every jurisdiction has rules. What determines how those rules are applied – the timing of engagement, the tolerance for ambiguity, the willingness to work through uncertainty with me – is the philosophy sitting underneath them. The US regulatory model, particularly in financial services, operates on a philosophy of permissiveness with enforcement backstop. I am broadly allowed to innovate, and the system corrects through action after the fact. The EU and UK model is built on a philosophy of pre-emptive assurance. The regulator wants confidence before I build momentum, not accountability after I have it. Neither philosophy is superior. But confusing one for the other is where serious exposure lives. Proactive engagement is not a soft skill in the EU – it is a market entry strategy. The assumption most founders carry into European regulatory engagement is that more rules mean slower progress. The opposite is often true. Because EU and UK regulators expect pre-engagement, they are structurally set up to give it to me. The FCA’s innovation pathways, the sandbox frameworks, the pre-application guidance – these exist because the philosophy demands proactive dialogue. If I use them properly, I arrive at launch with documented regulatory alignment rather than undisclosed risk. That is not a slower path to market. That is a cleaner one. The regulator does not surprise me. I surprise myself. This is the thing I keep coming back to. In both markets, the regulator behaved exactly as their published guidance, their public speeches, and their prior enforcement actions would have predicted. I was the one who had not read the signals correctly. I had read the rules. I had not read the character of the institution. Those are different things, and the gap between them is where most cross-border regulatory failure actually happens. What This Means If You Are Building Across Jurisdictions Now If I am running a fintech, a GRC platform, or any regulated product across more than one geography, the question is not whether I have legal coverage in each market. The question is whether the person responsible for regulatory strategy in each market has genuine fluency in how that regulator thinks, not just what it requires. Rules can be read by a good lawyer. Philosophy has to be learned through proximity – through pre-meetings, through sandbox engagement, through understanding what a regulator has said in its last five public consultations and why. The organisations I have seen handle multi-jurisdictional launches well share one common trait: they treat regulatory engagement as a relationship to be built before it is needed, not a process to be managed after something goes wrong. That requires time, and it requires the kind of senior attention that often gets deprioritised in favour of product and commercial priorities. I have made that deprioritisation myself. I am not exempt from the lesson. It also requires the kind of honest internal culture where the compliance team feels genuinely empowered to raise a concern before launch, not after. That is a different conversation – one I have written about elsewhere – but it is inseparable from this one. The Closing Thought Two regulators, one product, entirely different outcomes – and the difference had nothing to do with the quality of what
Quantitative Tightening and the Macroeconomic Reality
When the System Tightens: What Quantitative Tightening Actually Does to Your Risk Models I was sitting across a conference table from the risk team at a mid-sized asset manager in late 2022. Good people, experienced people, the kind of shop that had weathered 2008, navigated the COVID volatility, and built their frameworks carefully over two decades of hard lessons. We were reviewing their liquidity stress scenarios, the kind of exercise that, in most years, is professionally useful without being professionally urgent. Their models looked fine, their buffers looked more than adequate. I ran the numbers three times, not because anything was wrong, but because the results seemed too comfortable for the environment we were sitting in. The Bank of England had been raising rates, the Fed was well into its tightening cycle. Quantitative tightening, the deliberate reduction of central bank balance sheets after years of extraordinary expansion, had been underway for months. And yet everything on those spreadsheets looked orderly. I should have trusted the discomfort more than the spreadsheets. The Situation The problem with QT is that it is not a single event I can model. It is an atmospheric change. Between 2009 and 2021, central banks globally expanded their balance sheets to an almost incomprehensible degree, the Fed alone went from roughly $900bn to over $8 trillion. That capital had to go somewhere, it found its way into asset valuations, into compressed credit spreads, into the quiet assumption baked into almost every risk model that liquidity was ambient, that it was simply there, like oxygen. What QT does is reduce the oxygen concentration, slowly, incrementally. And because the reduction is gradual, the feedback loop is delayed, which is precisely what makes it dangerous. By Q1 2023, the asset manager I had been advising was seeing things that their models had not flagged as probable. Refinancing costs had jumped in ways that ate into assumptions built during a period of structurally different rates. Counterparty appetite had thinned, not dramatically, not catastrophically, but perceptibly. Two positions they had classified as liquid turned out to be liquid in theory and illiquid in practice. There was no single headline event, no Lehman moment, nothing had broken, everything had just become slightly harder, simultaneously, across every dimension that mattered at once. I remember one of the senior risk managers saying, with a kind of tired accuracy: “We planned for the doors to get narrower, we did not plan for all of them to get narrower at the same time.” That line stayed with me, because it was exactly right, and it described something that conventional stress testing, built around individual shock scenarios, is structurally ill-equipped to capture. Three Things QT Does That the Rates Headline Doesn’t Tell You **First: it changes what “liquid” means.** In a QE environment, markets are deep because central bank purchases create a persistent buyer with no return requirement. Remove that buyer and liquidity becomes conditional, it exists when sentiment is stable and disappears precisely when you need it most, which is to say, when sentiment isn’t. Assets that traded freely in 2020 and 2021 carried liquidity assumptions that were products of that specific environment, those assumptions did not automatically update when the environment changed. The models were not wrong, they were answering a question that no longer reflected reality. **Second: the transmission lag is long enough to be genuinely deceptive.** Rate rises are felt quickly, in mortgage costs, in corporate debt service, in consumer spending data. Balance sheet reduction works over a longer cycle, through the gradual withdrawal of reserve balances from the banking system and the slow repricing of risk appetite throughout the credit chain. This means institutions can operate inside deteriorating conditions for months before anything manifests in their numbers, the system tightens before the data tells you the system is tightening. By the time the evidence is visible, the adjustment window has narrowed considerably. **Third: QT interacts with everything else at once.** The rates shock was the headline, the balance sheet reduction was the mechanism running underneath it, invisibly. Taken alone, either would have been manageable for most well-run institutions, together, they changed the physics of the environment. Duration risk repriced, collateral values shifted, the correlation assumptions in multi-asset portfolios, correlations built during a decade of suppressed volatility, began to behave unexpectedly. Risk managers who had stress-tested each factor individually found themselves in a world where the factors had become entangled. What This Means for Your Organisation Right Now The question most risk functions are asking is whether they can survive a rate shock, that is the right question, but it is the second question. The first question is whether your liquidity assumptions, your correlation assumptions, and your counterparty models were calibrated in a world that no longer exists. For most institutions, the honest answer is: partially. The models were updated, but the underlying assumptions about how markets behave, how liquidity moves, and how correlated risk manifests were formed in an extended period of exceptional monetary accommodation. QT is not just a policy reversal, it is the removal of the conditions under which modern risk management frameworks were largely built and refined. Running those frameworks forward without interrogating their foundations is not risk management, it is institutional memory applied to a changed environment and called discipline. The asset manager I mentioned did not fail, they adapted, but later than they should have, and at greater cost than necessary. The lesson was not that their risk team was inadequate, the lesson was that the environment had changed its operating assumptions and nobody had formally updated theirs to match. Closing The market does not care when your models were last calibrated, and it is completely indifferent to the decade in which your assumptions were formed.
What Basel III Is Really Testing in Banks Today
When Passing Every Test Is Not the Same as Being Prepared I sat across from a risk committee in Q3 2022 that had done everything right on paper. Liquidity coverage ratio was above threshold, net stable funding ratio was solid, and capital filings were submitted on time, every quarter, without drama. The room carried the particular confidence of people who had followed the rules and knew it. Six weeks later, a rate shock hit. The CFO called me, and he was not panicking, which, looking back, made it worse. Panic I could have worked with. What he had instead was genuine bewilderment. “We passed every stress test, Laksh. How is this happening?” I gave him an honest answer in that call, but the question itself stayed with me for much longer. Because he was right, they had passed every test, and they were still unprepared. The gap, between the test and the reality, is what I have been thinking about ever since. The Situation Here is what their balance sheet actually looked like, beneath the ratios. I saw that the product team had spent eighteen months pushing into longer-duration liabilities because the margins were attractive. Treasury had flagged concerns internally, twice. Both times the conversation ended when someone cited the capital ratios as evidence the position was sound. I decided that the stress tests had been produced by a small team, reviewed by risk, filed with the regulator, and essentially not touched again until the next cycle. I also decided that capital planning happened once a year, in a process the business units attended long enough to sign the assumptions and then left. No one had broken a rule. Every number was real. I followed the framework with genuine diligence. However, I did not think. The stress tests were treated as a compliance artefact, something I produce for the regulator, not something I use to make a better decision the following Monday. When the rate environment shifted faster than the annual cycle had modelled, there was no mechanism to catch it. The treasury desk and the product desk had been living in parallel universes, and Basel III had given them enough paperwork in common to feel like they were collaborating. I say with no pleasure that a bank can be a model Basel III institution and still be structurally unprepared for a real-world shock. I designed the framework to be rigorous, but I also implemented it in a way that is backward-looking. Filing last quarter’s ratios tells me where I was. It tells me almost nothing about where the next decision is taking me. Three Things That Conversation Confirmed **Resilience is an operating discipline, not a reported state.** I noticed that the institutions that held through the 2022 rate environment shared something: risk was not a department I consulted after the fact. It was a presence in the room when the product got priced, when the liability structure got approved, when the assumption about customer behaviour got embedded in a model. The ratio I filed was a consequence of the thinking that had already happened. Not the other way around. Most banks have inverted this. I use the ratio to justify decisions already made. When the ratio looks acceptable, the conversation stops. That is not risk management. That is risk rationalisation. **Stress testing works only if someone owns the result.** I found that the problem with how stress testing is practised in the majority of mid-sized institutions is not the methodology. The models are often genuinely sophisticated. The problem is what happens the morning after the document is filed. I ask myself, who reads it? Who changes something because of it? In that 2022 committee, the answer was effectively no one, not because they were negligent, but because the process had no forcing function attached to it. Stress testing had become a production exercise. A skilled team spent weeks building a credible scenario, and the output lived in a folder. I believe that stress testing earns its cost only when it is connected to a decision. When a scenario changes a pricing assumption, modifies a product approval, or triggers a board conversation about exposure, that is when it does the thing it was designed to do. Otherwise, it is expensive documentation. **Capital planning done annually is capital planning done wrong.** I think that the world that Basel III was designed for no longer moves at an annual cycle. Rate environments shift in quarters. Funding markets can reprice in weeks. The assumption embedded in most capital planning processes, that I review the balance sheet once a year in a structured exercise, is structurally mismatched with how risk actually arrives. It arrives continuously. It arrives in product decisions and pricing decisions and hiring decisions and the small assumptions that compound quietly until one external event makes them visible all at once. I have seen that the institutions that navigate volatility most effectively treat capital planning as a standing discipline with a live component, regular, shorter reviews that connect the balance sheet to the decisions being made now, not the decisions made last autumn. What This Means for Your Organisation If you are a CFO, a CRO, or a board member reading this, the question worth asking is not whether your ratios are in order. They probably are. The question is whether the people approving products, pricing liabilities, and building forecasts have ever been in the same room as the stress test output. Whether your capital planning process ends when the document is filed or when the business has changed something because of it. Whether your treasury desk and your product desk are genuinely in conversation before the decision, or only after the loss has been recognised. The answer to that question tells me more about your resilience than any number you will report this quarter. I gave the industry a language for resilience. What I cannot mandate is whether you use it to think or merely to report. The banks that
Asia changed my perspective
What Six Months in Asia Taught Me About the Limits of My Own Experience I stepped off a plane in Hong Kong in early 2025, carrying twenty years of assumptions about how regulated industries work, how risk is managed, how governance frameworks are built, and, if I am honest, about where the serious thinking in financial services actually happens. I had built a career in London, operated across EMEA, navigated Basel frameworks, sat in front of regulators in three time zones. I thought I had a reasonably accurate map of the global landscape. By the time I landed back at Heathrow six months later, that map was in pieces on the floor. This is not a story about being humbled by the exotic East. That framing is its own form of condescension, and it is not what happened. What happened was more specific, and more uncomfortable: I discovered that some of the hardest problems I had spent years advising organisations to manage had already been solved – operationally, not theoretically – in places I had been too comfortable to spend serious time in. The Moment I Stopped Being Certain The jolt came in Singapore, about six weeks into the trip. I was in a working session with a team running AI governance infrastructure for a major financial institution. Not a pilot, not a roadmap: live infrastructure, being stress-tested against real regulatory requirements in real time. The team lead was explaining their model validation approach – the controls architecture, the feedback loops, the way they had structured human oversight into the decision chain – and I was taking notes like a junior analyst. She was thirty-two, maybe thirty-three. In London, the person with that responsibility is usually someone with grey hair, institutional scar tissue from a crisis or two, and a carefully curated network of regulators they can call. Experience is used as a credential. Here, the credential was demonstrated capability. The question the organisation had asked was not “who has done this before?” It was “who can actually do this now?” I have spent two decades in rooms where seniority determines credibility. That session in Singapore was the first time in a long while that I felt the distance between my assumptions and reality as a physical thing. Three Things That Refused to Fit My Existing Model I started in Hong Kong, because it was where the dissonance started. The regulatory environment there operates at a pace I was not prepared for. In London, the gap between regulatory intent and enforcement action can stretch across years – consultations, industry responses, phased implementation, guidance notes on the guidance notes. In Hong Kong, that gap is measured in weeks. The senior executives I met were doing something I found genuinely rare: they were holding two entirely different regulatory worldviews simultaneously – mainland and international – without it visibly destabilising their decision-making. That is not a skill most frameworks teach. It is the product of operating under sustained complexity for long enough that ambiguity becomes a normal working condition rather than a problem to be resolved before you proceed. Singapore was infrastructure where I expected aspiration. AI governance in that market is not a strategy document. It is funded, staffed, and running. The Model Risk Management frameworks had been adapted specifically for generative AI contexts – not retrofitted from credit risk models from 2009, which is what I see most often in European institutions. The regulatory bodies had developed technical capacity in parallel with the private sector, not after it. That sequencing matters more than most governance discussions acknowledge. Tokyo took longer to read, but it had the most to say about execution. The pace was slower. Consensus takes the time it takes, and there is no shortcut that does not eventually cost you. But the data governance practices I observed had a quality I had genuinely not expected: they were operational, not decorative. There was no gap between policy and practice, no shelf full of frameworks that the business quietly ignores. The controls were embedded in how work actually happened. In my experience across UK and European financial institutions, that gap – between the governance document and the governed reality – is one of the most persistent and expensive problems in the industry. In the organisations I visited in Tokyo, it had been closed. They were not debating data quality. They had built systems that made low-quality data structurally difficult to introduce. The Thought That Arrived Somewhere Over the Gulf On the third return leg – somewhere between Dubai and London, around 2am – something settled. Asia is not catching up to Western regulatory and governance thinking. That framing assumes the West defined the destination and everyone else is navigating toward it. What I had actually witnessed was a set of jurisdictions solving problems that the West has not yet named clearly enough to begin solving. The West is good at frameworks. I write them, export them, consult on them, and convene conferences about them. The frameworks are often genuinely rigorous. But a framework without the infrastructure to run it is a very expensive piece of intellectual comfort. What I saw in those six months was the infrastructure – built with urgency, staffed for capability rather than seniority, and designed to adapt rather than to endure. What This Means for Anyone Leading in Risk, Compliance, or AI If my organisation is building AI governance, updating its model risk framework, or trying to understand how regulatory expectations are shifting globally – the most useful thing I can do is not commission another benchmarking report from a global consultancy. Those reports will tell me what was true eighteen months ago, filtered through a lens that probably originated in Western financial centres. I will go. I will sit in the actual rooms. My education begins the moment I clear customs and starts to compound when I realise how many of my own assumptions were doing work I never asked them to do. The competence