Solving the mischief
09 Jul 2025
Multrees’ chief risk and compliance officer Rachel Robertson talks to Jack McRae about her fascination with rules, current regulatory trends and how her role is evolving with technology
Image: Multrees
All Rachel Robertson wanted to do when she was younger was have a corporate job. “That sounds really sad and I appreciate how silly the dream is,” she laughs. “My family moved to Texas because my dad was in oil and gas and while we were there, there was a ‘Take Your Daughter to Work Day’. I went to my dad’s office and I instantly fell in love with office living.”
The chief risk and compliance officer at Multrees has been involved in finance for close to 15 years, beginning her journey as an audit manager at Deloitte. Yet, having studied law at university, Robertson always wanted to return to understanding the “mischief”.
She explains: “I loved the law degree and one of my courses was how law is written, and going back to the mischief. In the legal sense, why are we putting this law in place? What’s the mischief we’re trying to address?”
Robertson continues to explain that this principle has remained her guiding principle throughout her time at Multrees. From joining as a financial controller, she has also held the position of head of finance, risk and compliance, and is now chief risk and compliance officer.
“Every rule that we talk about we draw it right back to that mischief, and it goes back to that point that it makes it all real. We are really helping somebody. We exist to tackle that mischief of them not wanting to have a whole extra set of rules to deal with,” she says.
Balancing act
Robertson’s knowledge and understanding of regulation is palpable and she lights up at the mention of consumer duty. “I find it really hard to believe it’s been two years. I know we’ve been talking about it for four or five years, but two years from the anniversary feels wild. Time really does fly,” she says.
She explains that she had expected the regulation to have been trimmed and narrowed in that time, but, she suggests, “the fact that we haven’t is an indication that it has worked.”
The approach to consumer duty is reflective of what Robertson believes is a pattern in the Financial Conduct Authority’s (FCA) approach to implementing new rules. “The two extremes of the spectrum of FCA output at the moment is either the broadest or the most specific,” she explains. “I think they’re going to stay at those sort of fair ends of that spectrum.”
Does she believe that strategy is working? “It feels like it’s working. For example, for crypto, they couldn’t have come out on that broad end of the spectrum, because it’s too complicated. There is too much that can go wrong and crypto is already rife for fraud and abuse,” she replies.
One of the hardest challenges for regulators is finding the balance between transparency and efficiency. Robertson believes that that balance is “absolutely” tricky and adds: “The data requirement is only going to increase and although we might be in a little phase where they’re saying, ‘You don’t need to give us this data’, the reality of it is there is no way that we are not moving towards, in 5, 10, 20 years’ time, all this data must be available.
“When you think about transaction reporting, there could be 100 data points about that transaction and if you’ve suddenly got to produce all these 100 data points, in the right order, in the right place, in the right format, that will be tricky.”
When asked how firms should consider their approach to the ever-increasing importance of data, Robertson kept it simple. “It’s got to be back to basics and build from basics,” she says. “You need to make sure that the data warehouse is the strong foundation for absolutely everything that you do.”
The perfect gap
Looking into the future, it is difficult to see a financial services industry not heavily reliant on artificial intelligence. At the heart of that evolution lies the importance of accurate data.
“We’ll have achieved bingo by mentioning AI,” Robertson jokes.
“But that is something that people are talking more and more about. AI is all about data. All of the difficulties in implementing AI are about the data going in. If you don’t have the security of data, then you can’t use AI.”
AI is not just of interest to the asset servicing industry, Robertson and Multrees are paying particularly close attention to the ways in which they can use the rapidly evolving technology in their work processes.
“In the next five years, I want to really get into the compliance side of AI and the ethics,” she says. “We’re having very, very early conversations about AI. We’re thinking about how we can better line up our data, how we can get more data in, how we can get multiple data sources and build that out so that we have that super exciting, strong foundation.”
One of the key points of regulation dominating discussions, interviews and meetings is the UK’s shift to a shorter settlement cycle on 11 October 2027. The necessity to bring in automation and AI-powered technologies to help cope with the pressures of trades being settled in a shorter time frame.
Robertson is already looking beyond 2027 and T+1. “We’ve been talking about accelerated settlement for the past couple of years. We’re going to be talking about, and I’m thinking more about, anticipatory settlement,” she explains.
Robertson draws similarities of anticipatory settlement with viral social media videos. “It is like those satisfying videos where something fits perfectly into something, and it just slides away and it’s gone,” she explains. “I think that’s where we need to move with settlement. Everything we’ve done for accelerated settlement is on those lines. It is making sure that the perfect gap exists for the settlement, so that all you need to wait for is the things sliding over and falling into the gap that you’ve created for that settlement to happen.”
Returning to the idea of the mischief, Robertson believes the mischief that must be solved is how to make that ‘perfect gap’.
“For anything that we do, we need to make sure that we’re doing all of the prep so that we’re just ahead of the thing that’s happening. So when it does happen, we’re ready for it, and we’ve got everything that we need.”
Buying eggs
“I wouldn’t want to draw direct correlations, but if we take everything that’s been happening geopolitically over the past 10 years — we’ve even had a pretty tough time in the past month — there is probably an alignment to the focus of ESG versus that very broad alignment of how left and how right the world or any given country is at any given time,” Robertson explains.
The impact of geopolitical tensions is more of a concern for the front office and investment managers, but Robertson admits there is still an element of concern she has to maintain. “The security of the assets is paramount,” she says. “It’s what any grey hair I might have is due to. We need to make sure that we are prepared for whatever that might look like.
“I’m not suggesting anything of the sort, but my dad used to always talk about how they would build data centers outside of the M25 and the reason is bombs. It’s wild that you even have to think about that, but you don’t build a data centre or any key infrastructure inside the M25 because that would be a problem in the absolute worst case scenario.”
Robertson admits that she is having to consider worst case scenarios “a lot more”, but those worries are limited to just having plans in place for those instances rather than “spending too much energy worrying around that.”
One key area of regulation that has fallen from prominence in recent years, reflected in a right-wing shift, is ESG.
Asked whether she believes it is still an important topic for firms and regulators, Robertson shrugs: “I think it remains a focus for the people for whom it is a focus. What I mean by that is, beyond the regulation it probably didn’t matter to some people. They decided that, although it’s important, they might have nodded towards it, it wasn’t going to be the most performance enhancing way of doing things morally better.”
A change in that attitude is unlikely too, Robertson suggests. “I’m not going to say it’s ended up a niche, but it’s ended up a product as opposed to a lifestyle. You can choose to buy free range eggs, it is an option, but if you don’t care, you’re just going to get whatever eggs look nicest or cheapest.
“With ESG, it is an option, but if you don’t care then you don’t care beyond the rules. Obviously, rules help a little bit, but until the FCA or another country’s regulator says: ‘We want to be the most ESG friendly. We want this to be at the top of everyone’s list,’ you’re leaving it up for optionality.”
Ultimately, Robertson believes that unless end consumers drive a shift towards ESG-centred investments, there is unlikely to be a return of ESG to the forefront of the industry’s discussions.
“You can hope that, but if they’re not motivated by that, you could force people to be motivated by it, but we’re not in that position,” she admits.
Whether it is to return to the heart of developing regulations in the near or distant future, Robertson will no doubt be on the lookout for yet more mischief to solve.
The chief risk and compliance officer at Multrees has been involved in finance for close to 15 years, beginning her journey as an audit manager at Deloitte. Yet, having studied law at university, Robertson always wanted to return to understanding the “mischief”.
She explains: “I loved the law degree and one of my courses was how law is written, and going back to the mischief. In the legal sense, why are we putting this law in place? What’s the mischief we’re trying to address?”
Robertson continues to explain that this principle has remained her guiding principle throughout her time at Multrees. From joining as a financial controller, she has also held the position of head of finance, risk and compliance, and is now chief risk and compliance officer.
“Every rule that we talk about we draw it right back to that mischief, and it goes back to that point that it makes it all real. We are really helping somebody. We exist to tackle that mischief of them not wanting to have a whole extra set of rules to deal with,” she says.
Balancing act
Robertson’s knowledge and understanding of regulation is palpable and she lights up at the mention of consumer duty. “I find it really hard to believe it’s been two years. I know we’ve been talking about it for four or five years, but two years from the anniversary feels wild. Time really does fly,” she says.
She explains that she had expected the regulation to have been trimmed and narrowed in that time, but, she suggests, “the fact that we haven’t is an indication that it has worked.”
The approach to consumer duty is reflective of what Robertson believes is a pattern in the Financial Conduct Authority’s (FCA) approach to implementing new rules. “The two extremes of the spectrum of FCA output at the moment is either the broadest or the most specific,” she explains. “I think they’re going to stay at those sort of fair ends of that spectrum.”
Does she believe that strategy is working? “It feels like it’s working. For example, for crypto, they couldn’t have come out on that broad end of the spectrum, because it’s too complicated. There is too much that can go wrong and crypto is already rife for fraud and abuse,” she replies.
One of the hardest challenges for regulators is finding the balance between transparency and efficiency. Robertson believes that that balance is “absolutely” tricky and adds: “The data requirement is only going to increase and although we might be in a little phase where they’re saying, ‘You don’t need to give us this data’, the reality of it is there is no way that we are not moving towards, in 5, 10, 20 years’ time, all this data must be available.
“When you think about transaction reporting, there could be 100 data points about that transaction and if you’ve suddenly got to produce all these 100 data points, in the right order, in the right place, in the right format, that will be tricky.”
When asked how firms should consider their approach to the ever-increasing importance of data, Robertson kept it simple. “It’s got to be back to basics and build from basics,” she says. “You need to make sure that the data warehouse is the strong foundation for absolutely everything that you do.”
The perfect gap
Looking into the future, it is difficult to see a financial services industry not heavily reliant on artificial intelligence. At the heart of that evolution lies the importance of accurate data.
“We’ll have achieved bingo by mentioning AI,” Robertson jokes.
“But that is something that people are talking more and more about. AI is all about data. All of the difficulties in implementing AI are about the data going in. If you don’t have the security of data, then you can’t use AI.”
AI is not just of interest to the asset servicing industry, Robertson and Multrees are paying particularly close attention to the ways in which they can use the rapidly evolving technology in their work processes.
“In the next five years, I want to really get into the compliance side of AI and the ethics,” she says. “We’re having very, very early conversations about AI. We’re thinking about how we can better line up our data, how we can get more data in, how we can get multiple data sources and build that out so that we have that super exciting, strong foundation.”
One of the key points of regulation dominating discussions, interviews and meetings is the UK’s shift to a shorter settlement cycle on 11 October 2027. The necessity to bring in automation and AI-powered technologies to help cope with the pressures of trades being settled in a shorter time frame.
Robertson is already looking beyond 2027 and T+1. “We’ve been talking about accelerated settlement for the past couple of years. We’re going to be talking about, and I’m thinking more about, anticipatory settlement,” she explains.
Robertson draws similarities of anticipatory settlement with viral social media videos. “It is like those satisfying videos where something fits perfectly into something, and it just slides away and it’s gone,” she explains. “I think that’s where we need to move with settlement. Everything we’ve done for accelerated settlement is on those lines. It is making sure that the perfect gap exists for the settlement, so that all you need to wait for is the things sliding over and falling into the gap that you’ve created for that settlement to happen.”
Returning to the idea of the mischief, Robertson believes the mischief that must be solved is how to make that ‘perfect gap’.
“For anything that we do, we need to make sure that we’re doing all of the prep so that we’re just ahead of the thing that’s happening. So when it does happen, we’re ready for it, and we’ve got everything that we need.”
Buying eggs
“I wouldn’t want to draw direct correlations, but if we take everything that’s been happening geopolitically over the past 10 years — we’ve even had a pretty tough time in the past month — there is probably an alignment to the focus of ESG versus that very broad alignment of how left and how right the world or any given country is at any given time,” Robertson explains.
The impact of geopolitical tensions is more of a concern for the front office and investment managers, but Robertson admits there is still an element of concern she has to maintain. “The security of the assets is paramount,” she says. “It’s what any grey hair I might have is due to. We need to make sure that we are prepared for whatever that might look like.
“I’m not suggesting anything of the sort, but my dad used to always talk about how they would build data centers outside of the M25 and the reason is bombs. It’s wild that you even have to think about that, but you don’t build a data centre or any key infrastructure inside the M25 because that would be a problem in the absolute worst case scenario.”
Robertson admits that she is having to consider worst case scenarios “a lot more”, but those worries are limited to just having plans in place for those instances rather than “spending too much energy worrying around that.”
One key area of regulation that has fallen from prominence in recent years, reflected in a right-wing shift, is ESG.
Asked whether she believes it is still an important topic for firms and regulators, Robertson shrugs: “I think it remains a focus for the people for whom it is a focus. What I mean by that is, beyond the regulation it probably didn’t matter to some people. They decided that, although it’s important, they might have nodded towards it, it wasn’t going to be the most performance enhancing way of doing things morally better.”
A change in that attitude is unlikely too, Robertson suggests. “I’m not going to say it’s ended up a niche, but it’s ended up a product as opposed to a lifestyle. You can choose to buy free range eggs, it is an option, but if you don’t care, you’re just going to get whatever eggs look nicest or cheapest.
“With ESG, it is an option, but if you don’t care then you don’t care beyond the rules. Obviously, rules help a little bit, but until the FCA or another country’s regulator says: ‘We want to be the most ESG friendly. We want this to be at the top of everyone’s list,’ you’re leaving it up for optionality.”
Ultimately, Robertson believes that unless end consumers drive a shift towards ESG-centred investments, there is unlikely to be a return of ESG to the forefront of the industry’s discussions.
“You can hope that, but if they’re not motivated by that, you could force people to be motivated by it, but we’re not in that position,” she admits.
Whether it is to return to the heart of developing regulations in the near or distant future, Robertson will no doubt be on the lookout for yet more mischief to solve.
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