Stage 2 Proposal: Implementation
The owned data core, the automated ingestion layer, and the AI layer: built, integrated and adopted by the end of February 2027
1Where we are
Stage 1 delivered three documents (current-state and gap report; future-state technology strategy and operating model; transformation roadmap) and a review cycle that produced 23 points of written feedback from the Group, all of which were resolved and shipped into the revised deliverables on 14 July 2026. The direction is settled: the Group's problem is not the absence of a system of record; it is that data reaches the system of record by hand. Stage 2 builds the layers that fix capture, hold the Group's own master data, and put automation and AI on top of it. The specialist systems stay, as swappable spokes around a record the Group owns.
The programme completes before the end of February 2027. The close was moved from 31 December at the Group's 15 July review, to reduce delivery risk and to respect the Group's bandwidth through 1 October. The plan is sized for a start no later than Monday 3 August 2026.
2Objectives
One record per client and per connected party, replacing entity-by-entity re-keying, and covering the Rethink-only and RAA-only clients that today never fully reach the entity-management system.
Intake, screening and document data land in the record without manual entry. Manual data entry becomes the exception with a reason attached.
The Group sees working automation before the core build lands.
Document production, reporting and drafting; not where judgement is the product (tax opinions, audit conclusions).
Trained teams, defined roles, documented systems, and a steady-state model agreed before we leave.
3Target architecture
Read the architecture from the centre out, not top to bottom: the owned data core is the source of truth, and everything else is either an input to it, a spoke around it, or a layer on top of it. This is the same architecture the Stage 1 Future State report set as its central theme, carried forward unchanged into the build.
| Layer | What it holds and does |
|---|---|
| Capture and ingestion | KYC360 intake and screening; document OCR with a recheck that client-keyed data matches the source PDFs; BAU documents arriving by email through the same input layer; client portal forms. Everything is extracted, validated and written once. |
| Owned data core the source of truth | The Group master record: clients, entities, connected parties (UBO, shareholder, officer), fee data, obligations, under a single enforced identifier. R&C client deliverables do not sit in the Group's owned record; they are housed on a separate tenant of the record system, with appropriate firewalls between tenants. This segregation was raised in the Stage 1 review, is non-negotiable, and is designed in from day one. Audit data follows the same pattern: its own tenant (the audit tool serves roughly 15 of the ~300 entities, the ADGM-regulated ones), linked to the record at entity level so it never blocks the core data model. The boundary with accounting is equally deliberate: only limited metadata (client, period, invoiced or not) enters the record; ledgers and invoices stay in the accounting tools. |
| Specialist spokes swappable, none load-bearing | The entity-management platform, the CRM, the accounting tool and the screening tool, all selected in the WS0 evaluation (ViewPoint, Xero, KYC360, ComplyAdvantage and Inflo are today's estate and remain contenders), each connected through a governed integration and each replaceable without touching the record. |
| Workflow and AI layer | Document generation, renewals and filing logic, compliance calendars, proposal production, fiduciary review drafting; AI assistants at the desktop, governed and human-reviewed. |
| Reporting off the record | Regulator reporting, management reporting, operational reporting, sourced from the owned layer so it survives a change of platform. |
This is not a rebuild of ViewPoint or Quantios, and it does not replicate their application functionality. It is a data layer the Group owns, feeding the external systems around it; entity-management workflow, screening and finance functionality continue to live in the specialist tools. We build only where existing technology cannot provide the solution. This was the Group's central challenge in the Stage 1 review, and the boundary is stated on this page deliberately.
And read left to right, the same architecture is a single flow: data enters once at the boundary and moves out to every tool and report without ever being re-keyed.
Hosted in the region, portable by design
The owned core runs on a sovereign stack hosted in the region: UAE preferred, with options in Saudi Arabia, Oman and Abu Dhabi, and backups split between Dubai and Abu Dhabi. The architecture is built sandbox-first and deployed plug-and-play, so it can move between regional data centres without rework; that same portability is why the quick wins are not blocked by any hosting decision. Running costs (hosting, storage on AWS or MongoDB-class platforms, AI models and token usage, and tenancy) are set out in a separate cost note, with one-time and recurring costs distinguished and the capex and opex candidates flagged, so there are no budget surprises later.
4Scope of work: six workstreams
Six workstreams run staggered across the thirty weeks. WS0 opens with the systems evaluation and the baseline; WS5 runs the whole way; everything else overlaps by design, and the heavier Group-side work is scheduled after the bandwidth constraint lifts on 1 October.
WS0 · Systems evaluation, selection and mobilisation (weeks 1–4)
- One evaluation framework, four tool categories: entity management, CRM, accounting, and compliance screening (KYC360 vs ComplyAdvantage, taken as an early decision). Every candidate is scored on the same tests, interoperability first, so the selected tools' APIs speak the same language and nothing is chosen in sequence that mismatches later. The direction, an owned core with specialist spokes, is already decided; WS0 picks the spokes.
- ViewPoint is a contender, not the default. Candidates are benchmarked against it, with its known constraints on the table: the support window (~12 months), the missing API infrastructure that gates customisation, and the completed KYC360 API on the upgraded version. The Stage 1 capability matrix (Appendix B of the Future State report) is the starting decision paper.
- Two weeks of technical benchmarking inside a four-week selection window: the technical work completes in the first fortnight; the second fortnight carries the demos, reference calls and decisions at the pace the team's availability allows. Selection closes Friday 28 August.
- Kickoff in the first week of August: a consolidated kickoff presentation, and a baseline time study that repeats the end-to-end onboarding observation from discovery (measured then at roughly 12 hours of client time) under the WS0 measurement framework, alongside time-and-motion samples across regulatory compliance, corporate secretarial, audit, tax and accounting work. No benefit is claimed in this proposal that is not measured here first.
- A parallel data kickoff with the Group's data team, to align on the prior two months of data work, naming fixes, the client card definition and the client tape outputs.
- Lock the data model and the tenancy design: the segregation boundaries for R&C client data and for audit data, signed off by the Group MLRO before build.
- Environments and access to today's estate (ViewPoint SQL, Xero, KYC360, document stores), security review, and the Stage 2 RAID log.
- Output: systems selected across the four categories; signed architecture and data model; baseline measurement pack; Release 1 backlog.
WS1 · Data foundation (weeks 2–20)
- Master data model build; owned record deployed (segregated tenants).
- Legacy CRM cleanse and standardisation (the "Ltd. vs Ltd" problem), de-duplication, unique party ID applied Group-wide. The ID already exists for M/HQ in ViewPoint; this workstream extends its enforcement to Rethink-only and RAA-only clients, including the connected parties (UBO, shareholder, officer) that are not recorded today.
- Migration and reconciliation; data quality dashboard and ongoing stewardship rules.
- Output: Group master record live, with a measured data-quality score against the Stage 1 baseline.
WS2 · Capture and ingestion layer (weeks 3–24)
- WS2 does not wait for WS0. The ingestion build starts in parallel against defined interface contracts: a spoke-agnostic write model, the required data points agreed by process of elimination, and connectors bound to whichever tools WS0 selects. Tool selection changes the connector, not the layer.
- Screening-led intake deployed for onboarding, periodic review and ownership/control changes, with BAU document flow (email-received documents) routed through the same layer.
- OCR and validation: keyed data checked against source PDFs before anything writes to the record.
- Straight-through write to the owned record and onward to the spoke platform.
- Fee-approval-to-invoice automation (removes the line-by-line re-keying between the entity-management and accounting systems).
- Output: intake and BAU changes captured once, entered once.
WS3 · Spoke configuration and integration (weeks 6–26)
- Configure the spokes selected at WS0; migrate; UAT (the heavier Group-side testing is scheduled after 1 October).
- Integrations: the selected entity-management spoke to the owned record; the selected screening tool; the accounting tool of choice; Inflo; BlueSky.
- Payroll flow (Excel to HRMS to the accounting tool) rebuilt so individual employee changes no longer require a full payroll rollback.
- Output: integrated landscape, no manual bridge files.
WS4 · Workflow automation and the AI layer (weeks 8–29)
- Document production: working papers, board minutes, corporate governance documents, structuring proposals (including the PowerPoint-to-HTML proposal change flagged in the Stage 1 review; tested for real productivity gain before it is committed).
- Renewals and filings: auto-roll of next-year filings, monthly renewal reporting.
- Compliance calendars generated from jurisdiction rules rather than rebuilt by hand.
- Annual accounting build on the record (no specialist tool covers it; a bounded build per the Stage 1 Future State report, Section 7.1): statement preparation off prepared data toward the team's own 8-to-4-hour goal, and FTA-compliant VAT/CT return generation, with the opinion staying with the professional.
- Fiduciary reviews (elevated to the ranked list in the Stage 1 review on risk grounds): bank-statement requests, review file notes and fee schedules as workflow and AI drafting off the record, human-reviewed at every point a regulator examines.
- Regulator and management reporting from the owned layer.
- Prompt library per function: regulatory compliance (authorisation policies and procedures, for example ADGM applications that today absorb 80 to 120 senior hours each, built from patterns in regulator-approved cases); tax advisory opinions; structuring advisory opinions; tax working papers and the audit (RA) items agreed at the 15 July review. Each library carries a usage governance policy, a security view, and a self-teaching feedback loop that folds reviewed outputs back in.
- AI tooling: hands-on training per function on the libraries and policy. The specific assistant platform (candidates include Microsoft Co-pilot and Anthropic Claude) is selected once the prompt libraries and policies are proven in use.
- Output: automation live in the functions where Stage 1 evidenced the load.
WS5 · Adoption, capability and steady state (weeks 1–30, continuous)
- Change and adoption programme by function; champions network; department-level KPIs.
- Training and education phase (weeks 20–30, led by the dedicated Training and Education Specialist): role-based curricula per function, hands-on workshops for the AI tooling and each new workflow as it goes live, train-the-trainer for the internal systems team and the champions network, quick-reference guides, and completion tracked per department so adoption is measured, not assumed.
- Role and job-description changes; capability framework.
- Recruitment support for the Group-side roles (Section 9).
- Steady-state operating model, support model, and handover pack, including the standalone technology seat and internalisation plan conditions from the Stage 1 Roadmap, restated in Section 9 of this proposal.
- Output: the Group runs it; CrossVal supports rather than drives.
5Deliverables and dates
| # | Deliverable | Workstream | Due |
|---|---|---|---|
| 1 | Systems selected across the four categories; signed target architecture, data model and tenancy design | WS0 | 28 Aug 2026 |
| 2 | Baseline measurement pack (pre-implementation) | WS0 | 28 Aug 2026 |
| 3 | Release 1: quick wins live (checkpoint 18 Sep; gate 30 Oct) | WS2, WS4 | 30 Oct 2026 |
| 4 | Group master record live, migrated and reconciled | WS1 | 11 Dec 2026 |
| 5 | Capture and ingestion layer live | WS2 | 15 Jan 2027 |
| 6 | Selected spokes configured and integrated; UAT signed off | WS3 | 29 Jan 2027 |
| 7 | Workflow and AI layer live; AI assistant rolled out with usage and governance policy | WS4 | 12 Feb 2027 |
| 8 | Fiduciary review workflow and drafting live | WS4 | 12 Feb 2027 |
| 9 | Annual accounting build live on the record (incl. FTA-compliant VAT/CT output) | WS4 | 19 Feb 2027 |
| 10 | Adoption programme complete | WS5 | 19 Feb 2027 |
| 10a | Training and education programme delivered: role-based curricula, hands-on workshops, train-the-trainer, quick-reference guides | WS5 | 26 Feb 2027 |
| 11 | Steady-state operating model and handover pack | WS5 | 26 Feb 2027 |
| 12 | Post-implementation measurement report (against the WS0 baseline) | All | 26 Mar 2027 |
6Release plan and timeline
Three gated releases, back-solved from the end-of-February close. Scope flexes; the date does not. A quick-wins checkpoint on 18 September shows working automation early; the R1 payment gate sits on 30 October, after the Group's bandwidth constraint lifts.
| Release | Window | Contents | Gate (end of window) |
|---|---|---|---|
| R1 · Quick wins | Mon 3 Aug – Fri 30 Oct | Monthly accounting ingestion; fee-approval-to-invoice and AR reporting automation; compliance calendar generator; regulatory-return answer library; file-note drafting; renewals reporting; prompt libraries and AI usage policy; recruitment note-taking automation | Steering go/no-go on R2 scope |
| R2 · Core | Mon 28 Sep – Fri 29 Jan 2027 | Owned data layer; migration; capture and ingestion; spoke configuration and integrations | UAT sign-off by function heads and Group MLRO |
| R3 · Automation, AI and steady state | Mon 30 Nov – Fri 26 Feb 2027 | Document production, reporting, fiduciary workflow, annual accounting build, AI layer, training and education, adoption, handover | Stage 2 close and steady-state entry |
The windows overlap deliberately: each release starts while the one before it is still closing, which is what keeps six workstreams inside seven months. The gate dates (30 Oct, 29 Jan, 26 Feb) are the commitments; the start dates are indicative until WS0 planning locks the backlog, and the December holidays are inside the R2 window, not squeezed against a year-end close.
7Quick wins: the first ten weeks
Named, dated, and owned. These carry no dependency on the WS0 systems selection, they are deliberately light on Group-side effort while bandwidth is constrained, and they are weighted toward the accounting, finance and compliance work where the time savings are largest. All are live before the 18 September checkpoint or the 30 October gate.
| Quick win | Function | Live by |
|---|---|---|
| Monthly accounting ingestion: building on the ingestion the accounting tool has begun delivering, toward the ~60% time-saving target the Group has set per client, with CrossVal's preparation and validation playbook adding savings on top | Accounting · all entities | 18 Sep |
| Fee-approval table to invoice, no line-by-line re-keying between systems | Finance · Deepthi/Ateeq | 11 Sep |
| AR reporting assembled automatically from exports, instead of extracted and cleansed by hand | Finance · Deepthi | 18 Sep |
| Compliance calendar generation from jurisdiction rules, replacing the annual manual rebuild | Reg compliance · Anna, Raja | 25 Sep |
| Reusable answer library for regulatory returns (~300 questions per authority, answered once and maintained) | Reg compliance · Raja | 2 Oct |
| Periodic-review file notes drafted for the compliance officer to review and complete | Reg compliance · Anna | 2 Oct |
| Monthly renewal report generated rather than assembled in Excel | Corp sec | 9 Oct |
| Function prompt libraries and an AI usage policy; the specific assistant platform is decided later, once the policies are proven | Group-wide | 9 Oct |
| Meeting notes, call summaries and scheduling automation | Recruitment | 9 Oct |
The compliance savings are counted honestly: a good share of the time these tools free is deliberately reinvested into review quality rather than removed, which is exactly where the Group wants it.
8Resourcing: CrossVal team
Ten specialists across the engagement: the build team surges through mobilisation and the core build, and a dedicated training and education phase carries the later weeks, tapering as the Group's own team takes over. The thirty-week window spreads the same hours more thinly than a year-end close would have, which is deliberate: it fits the Group's reduced bandwidth through 1 October and keeps the December holidays inside the plan rather than against it. Role hours are the indicative allocation within the fixed fee envelope; the final cut is locked at contracting against the WS0 backlog.
| Role | Rate (AED/hr) | Hours | Fee (AED) |
|---|---|---|---|
| Engagement Principal | 1,645 | 68 | 111,860 |
| Solution Architect | 1,315 | 158 | 207,770 |
| Delivery Manager | 935 | 132 | 123,420 |
| Data Engineer (lead) | 965 | 274 | 264,410 |
| Integration / Automation Engineer | 945 | 212 | 200,340 |
| AI Engineer | 1,015 | 138 | 140,070 |
| Business Analyst / Process Lead | 755 | 128 | 96,640 |
| Change and Adoption Lead | 845 | 72 | 60,840 |
| Training and Education Specialist | 655 | 126 | 82,530 |
| QA / Test Analyst | 545 | 88 | 47,960 |
| Total | blended 957 | 1,396 | 1,335,840 |
The build team is at full strength through mobilisation and the early build; from December the emphasis shifts to training, education and handover, and by February the Group is running the system with CrossVal in light support. The taper is the handover working.
Not inside the programme window. This is not two generalists for thirty weeks; it is slices of ten specialists, an architect, a delivery manager, data, integration and AI engineers, process, change, training and QA, who arrive on day one already carrying the Stage 1 context. Hiring even two of these profiles in the UAE takes three to six months, most of the runway, and they would join knowing nothing about the Group. The roles that are worth owning permanently are exactly the ones in Section 9, and this engagement helps hire and onboard them.
9Resourcing: Group side
The Group's project team (no fee, as allocated by the Group):
| Person | Role | Area of expertise | Stage 2 focus | Time |
|---|---|---|---|---|
| Greg | Project Sponsor | Overall strategy and operational guidance | Sets targets and objectives, reviews status, makes the final decisions | 60% |
| Serena | Project Manager | Finance, operations, systems; communication | Coordinates vendors, internal teams, and the interdependent project plans | 50% |
| Ateeq | Implementation team · M/HQ, Rethink, RAA | Finance and operations | Rethink data cleaning, platform implementation, workflow expert | 80% |
| Geetu | Implementation team · M/HQ, Rethink, RAA (Systems lead) | Operations and systems | M/HQ data cleaning, platform implementation, workflow expert | 80% |
| Raja | Internal Compliance Lead · Rethink, RAA | Rethink and RAA compliance | Data cleaning, platform implementation, workflow, internal and commercial compliance | 80% |
| Anna | Compliance Team Lead · M/HQ | M/HQ compliance | M/HQ workflow expert, internal compliance, strategic input | 12.5% |
| Deepthi | Finance Support | M/HQ and Rethink finance | Supports the finance workflows; supports Serena and Ateeq | 25% |
| Charu | External Finance Team Lead · Rethink | Rethink client finance | UAT and testing across multiple functions | 15% |
In addition the Group provides a named data owner per entity, function SMEs for design and UAT, and Group MLRO / compliance sign-off. Greg, as sponsor, turns decisions around inside 48 hours.
The hybrid-model conditions (from the Stage 1 Roadmap, Sourcing recommendations). The internal systems team (six people, currently reporting through Group Finance) takes ownership of bounded reporting and configuration on the record. Two conditions attach. First, the team needs a standalone technology seat rather than reporting through Finance; this is an operating-model change to make in Stage 2. Second, if the Group wants to internalise the core over time, Stage 2 carries an explicit hiring and capability plan for that team, sized so the handover is real rather than nominal.
The Group-side hires: four raised by the Group, one proposed by CrossVal
| Role | Our view | Duration |
|---|---|---|
| Master Data Architect | Interim from CrossVal from day one; internally, Geetu owns data architecture and develops under a structured learning plan from the CrossVal architect. This is the role that keeps the owned layer alive after we leave; do not outsource it permanently. | Interim CrossVal, then internal (Geetu) |
| Business Process Transformation Lead | Hire immediately; the full definition is below. Engaged from day one of Stage 2, or CrossVal covers the gap until the hire lands. | Permanent |
| Change Management / Adoption Lead | Serena coordinates: a weekly-cadence engagement with the function leads, with adoption metrics defined per function and hard KPIs. People-over-systems change management; a 6 to 9 month job, not a permanent one. | 6–9 months (Serena) |
| Platform implementation specialist | Tool-dependent, confirmed at the WS0 selection. The internal teams can compare tools against current workflows; designing the future AI-enabled workflows is the gap, and where internal capability is not available this defaults to CrossVal. | Contract / CrossVal by default |
| Growth / marketing role | Deprioritised at the 15 July review; left open for exploration. The case, turning the programme's efficiency gains into pipeline and deal flow, can be evaluated in a separate conversation; nothing in this proposal depends on it. | Open |
The Business Process Transformation Lead, defined
- A hands-on doer, not a coordinator: someone who changes how teams fundamentally operate, for example ensuring ADGM submissions run through the approved prompt libraries, with no sensitive data exposed, and outputs reviewed within set SLAs.
- Credible with senior managers: able to engage function heads directly and change working methods at their level, not only below it.
- Engaged from day one of Stage 2: involvement across the whole effort, identifying use cases early rather than arriving after the build.
- Grows into running the technology team: reporting to the owners rather than through Finance, with Geetu as the number two.
- Large-organisation digital-transformation experience: has carried operating-method change through an organisation of real size before.
- Distinct from change management: this role changes the operating method; the Change Management and Adoption Lead changes the culture around it. They are different jobs.
The transformation and adoption roles should not be collapsed into one person. Changing the operating method and driving adoption are different jobs, and the half that is not the person's core strength is the half that slips.
Reporting line. Technology reports to the owners, not through Finance; this is the standalone technology seat from the Stage 1 recommendation, made concrete. In the target model the Business Process Transformation Lead runs the technology team with Geetu as the number two; during Stage 2 the CrossVal engagement principal acts as the interim gatekeeper, separating mission-critical needs from noise.
10Governance and ways of working
- Steering committee (monthly). Greg (sponsor), Serena (project manager), Geetu (Systems lead), CrossVal engagement principal. Owns the release gates, the RAID log's high items, and the scope-flex decisions that protect the Q4 date.
- Delivery oversight (weekly). CrossVal delivery leads with Serena and Geetu, and function-head representation as the agenda requires. Tracks the release plan, clears blockers, reviews the measurement dashboard.
- Day-to-day delivery. CrossVal build team working alongside the Group implementation team (Ateeq, Geetu, Raja) with Anna, Deepthi and Charu as function anchors; decisions inside 48 hours via Greg.
Decision rights, escalation path and the RAID log are set in the WS0 mobilisation pack. Scope flexes; the date does not.
11Measurement framework
No projected savings appear in this proposal. Instead: WS0 captures a measured baseline (volumes, cycle times, touch counts, error and rework rates) across onboarding, renewals, invoicing, reporting and audit file prep. Targets are set against that baseline at the end of WS0 and reported monthly. The post-implementation report in January 2027 measures the same things the same way.
The Group's own observed figures from Stage 1 discovery are the calibration points, and each carries its source. These are validation targets the measurement framework tests, not benefits we claim.
| Observed figure | Source |
|---|---|
| Compliance put automated onboarding at roughly 90% of its work | Compliance team, discovery (Stage 1 Roadmap, Section 5.2) |
| Accounting's own goal: annual accounts from 8 hours to 4 per client, ~300 accounts | Accounting team, discovery (Stage 1 Roadmap, Section 3) |
| ~60 onboarding/KYC cases a month, M/HQ alone (new, refresh, BAU changes) | Group steering feedback, Jul 2026 (Stage 1 Roadmap, Section 3) |
| Regulatory returns of ~300 questions each across three supervisory authorities | R&C team, discovery (Stage 1 Roadmap, Section 3) |
| ~1,200 entities; ~200 staff; priority cluster holds ~72% of payroll | Group-supplied data (Stage 1 Roadmap, Section 5) |
12Fees and payment schedule
CrossVal fees
- Fees: AED 1,335,840 (fixed envelope; USD 363,741 at 3.6725), invoiced against the milestone schedule below. Hours are logged and reported for transparency, but the fee does not float with them.
- Less Stage 1 credit: (AED 132,210, being USD 36,000 at 3.6725), applied against the first invoice per the Stage 1 engagement terms.
- Net: AED 1,203,630 (USD 327,741 at 3.6725)
- Change budget (optional, drawn only against approved change requests): up to AED 133,584 (10% of the gross fee)
- Steady-state operate (hypercare, managed improvement or full managed service from January 2027) is contracted and priced separately, and runs as opex.
Overage and ceiling
The fee is fixed, so estimation risk sits with CrossVal, not the Group. The hour mix across roles will move as the work reveals itself, and misestimation up to 15% of the envelope is absorbed by CrossVal before any change request is even contemplated; in Stage 1, CrossVal absorbed an overage of roughly 18% and focused on outcomes rather than the hour mix, and the same posture carries into Stage 2. Change requests are reserved for genuine scope additions, such as specialist systems or equipment agreed after signature, and draw only on the optional change budget. That budget is also the ceiling: the Group's total exposure cannot exceed the fixed fee plus the change budget without a new signature.
Capex and opex: how the fee can be structured
The fee splits naturally into build and run, and the Group can elect to treat the two differently in its accounts.
| Treatment | What sits here | Why |
|---|---|---|
| Capex candidates one-off build and setup | The owned data core and ingestion-layer build; the integrations; data migration and conversion; and the tools and AI setup: assistant deployment and configuration, the function prompt libraries, the governance and security policy, and the training materials. | These create an enduring asset the Group owns and uses beyond the year of spend, which is what makes them candidates for capitalisation. |
| Opex recurring run costs | Software subscriptions and licences (including AI licences and usage), cloud hosting, ongoing support and the steady-state model, and training delivery as a recurring activity. | Consumed in the period; no enduring asset is created. |
The tools and AI setup is deliberately scoped to include both possibilities: the one-off setup elements are priced and invoiced as distinct deliverables so they can be capitalised if the Group elects to, while the recurring licence and usage costs run as opex. Final treatment is a Group accounting decision to take with its auditors under the applicable standards; CrossVal will structure the invoicing and the deliverable definitions to match whichever treatment the Group chooses, locked in the WS0 mobilisation pack.
Payment schedule
Percentages of gross fee; the Stage 1 credit is netted in milestone 1; the schedule recalculates if fees change.
| # | Milestone | % | Amount (AED) | Expected |
|---|---|---|---|---|
| 1 | Signature and mobilisation (net of Stage 1 credit) | 25% | 201,750 | 3 Aug 2026 |
| 2 | Release 1 live (quick wins) | 25% | 333,960 | 30 Oct 2026 |
| 3 | Release 2 live (core) | 25% | 333,960 | 29 Jan 2027 |
| 4 | Release 3 live + steady-state handover | 15% | 200,376 | 26 Feb 2027 |
| 5 | Post-implementation measurement report | 10% | 133,584 | 26 Mar 2027 |
| Total (net of credit) | 100% of gross | 1,203,630 |
Exclusions
Third-party software licences and vendor implementation fees; hardware; recruitment agency fees for Group hires; salaries of Group staff; data migration of records outside the agreed scope; ongoing run and support beyond the steady-state handover (priced separately); anything arising from a change of the spoke-platform decision after the WS0 gate.
13Risks and mitigations
| Risk | Mitigation | Owner |
|---|---|---|
| Systems selection not closed by 28 Aug | Four-week WS0 window with the two-week technical benchmark inside it; quick wins are selection-independent so the clock keeps running | Sponsor / Systems lead |
| ViewPoint support window closes within ~12 months | Forced into the WS0 decision paper, with cost of both routes | CrossVal |
| Spoke implementation slips (industry feedback on Quantios timelines is not encouraging) | Owned data layer is not dependent on the spoke going live; decoupled by design | CrossVal |
| Legacy CRM data quality blocks migration | Cleanse starts week 2, ahead of everything else | CrossVal / Systems lead |
| R&C client data cannot sit in the Group record (DP and segregation) | Separate tenant with firewalls between tenants, designed in WS0, signed off by the MLRO before build | Group MLRO |
| Stakeholder availability, the same constraint that bound Stage 1 | Named SMEs with committed hours in the mobilisation pack | Sponsor |
| End-of-February 2027 close | Three gated releases; scope flexes, the date does not | Steering |
| Group bandwidth constrained through 1 October | Quick wins scheduled to land with light Group-side effort; the R1 gate and the heavier UAT sit after the constraint lifts | Steering |
| Build-vs-buy maintenance burden: the owned layer needs ongoing expertise to evolve | Owned, not softened; carried from the Stage 1 Future State risk register: scope held to data, ingestion, integration and reporting; the steady-state model names who maintains it | CrossVal / Steering |
14Steady state and ongoing services
From March 2027 the Group runs day-to-day. The data-architecture owner (Geetu, developed under the Master Data Architect's learning plan) owns the data layer; the improvement backlog is governed by a quarterly technology forum; the technology team holds its standalone seat reporting to the owners; and if the Group elects to internalise the core over time, the hiring and capability plan from WS5 governs the handover.
Beyond the handover, CrossVal can provide ongoing services in whatever combination fits. The catalogue, so future commercial planning has something concrete to work from:
| Service | Cadence | What it covers |
|---|---|---|
| Hypercare | First 60 days after close | Rapid-response support while the new ways of working bed in: fixes, tuning, and hand-holding at the desk level. |
| Managed improvement | Monthly retainer | The improvement backlog worked continuously: new automations, integration changes, report evolution on the owned record. |
| Senior advisory | Monthly or quarterly | Engagement-principal level counsel to the owners and the technology lead: prioritisation, vendor decisions, roadmap. |
| Quarterly technology review | Quarterly | A structured audit of the estate against the measurement baseline: data quality, adoption, security posture, cost of run. |
| Prompt-library upkeep | Quarterly | Libraries re-certified against current regulator expectations, new patterns folded in from reviewed outputs, usage policy refreshed. |
Indicative ranges for these follow in the cost note, so they can be read alongside the hosting, storage and AI running costs rather than in isolation.
CrossVal is a build-capable technology firm recommending a model in which CrossVal builds and operates the core. That is disclosed. The internal and hybrid alternatives were laid out in Stage 1 with their real constraints so the Group could choose on the evidence, and the recommendation for hybrid rests on the internal team's observed size, not on CrossVal's interest. The Group owns the data throughout, so the operating partner can change without the record moving.
15Next steps
| # | Step | When |
|---|---|---|
| 1 | Revised proposal issued (this document) | 16 Jul 2026 |
| 2 | Cost note: hosting, storage, AI model and tenancy running-cost ranges (one-time vs recurring, capex vs opex) | w/c 20 Jul |
| 3 | Contracting and PO | by 31 Jul |
| 4 | Kickoff: presentation, baseline time study, and the parallel data kickoff | first week of Aug |
| 5 | Systems selected (WS0); quick-wins checkpoint follows 18 Sep | 28 Aug 2026 |
AAppendix: assumption log
Continues the assumption-log convention from the three Stage 1 deliverables; numbering restarts for this proposal.
| # | Assumption |
|---|---|
| 1 | Scope is Group-wide: M/HQ, Rethink and RAA. |
| 2 | Stage 2 starts Monday 3 August 2026 and completes before the end of February 2027 (revised from 31 December at the Group's 15 July review). The close governs: scope flexes, the date does not. |
| 3 | The owned-core direction from Stage 1 is decided; the systems selection (entity management, CRM, accounting, screening) closes at the WS0 gate, with ViewPoint a contender benchmarked against alternatives. |
| 4 | Volume and effort figures are as stated by the function heads in Stage 1 discovery, treated as observed rather than independently verified; the WS0 baseline measures them. |
| 5 | Role hours in Section 8 are the indicative allocation within the fixed fee envelope; the final cut is locked at contracting against the WS0 backlog. |
| 6 | The Stage 1 credit is applied per the signed Stage 1 engagement terms. |
| 7 | Third-party licences and vendor fees are client-contracted; vendor pricing for the selected systems is confirmed at WS0. |
| 8 | The hybrid-model conditions in Section 9 apply: a standalone technology seat for the internal systems team, and an explicit hiring and capability plan if the Group elects to internalise the core. |
| 9 | AI outputs examined by an external party are human-reviewed; judgement work (tax opinions, audit conclusions) stays with the professional. |
| 10 | The stack is regionally hosted (UAE preferred) on a sandbox-then-deploy, portable architecture; hosting, storage, AI and tenancy running costs are estimated in the separate cost note. |
BGlossary: key terms and acronyms
The engagement and its documents
| Term | Meaning |
|---|---|
| Stage 1 / Stage 2 | Stage 1 was the four-week tech and systems strategy, delivered July 2026. Stage 2 is the implementation this proposal covers, completing before the end of February 2027. |
| Gap Report | Stage 1 Deliverable 1: the Current-State Assessment and Gap Report. |
| Future State report | Stage 1 Deliverable 2: the Future-State Technology Strategy and Operating Model. Its Appendix B holds the Quantios/ViewPoint capability matrix used at the WS0 gate. |
| Roadmap | Stage 1 Deliverable 3: the Transformation Roadmap and Strategic Recommendations, including the sourcing recommendation this proposal executes. |
| WS0–WS5 | The six Stage 2 workstreams set out in Section 4. WS0 is the four-week systems evaluation and selection. |
| R1 / R2 / R3 | The three gated releases in Section 6: quick wins, core, and automation/AI/steady state. |
| Quick wins | Automations delivered in the first ten weeks that carry no dependency on the core build or the systems selection. |
The architecture
| Term | Meaning |
|---|---|
| Owned data core / golden record | The data layer the Group owns: one record per client, entity and connected party under a single enforced identifier. The source of truth; not an application. |
| Ingestion layer | The automated capture boundary: intake, OCR extraction and validation that turns documents and forms into structured data before it reaches the record. |
| Spoke | A specialist application connected to the owned record through a governed integration (entity-management platform, Xero, KYC360, Inflo, and so on). Swappable; none is load-bearing. |
| Separate tenant | A segregated instance of the record system. R&C client deliverables sit on their own tenant with firewalls between tenants, never inside the Group's own record. |
| Hybrid model | The Stage 1 sourcing recommendation: CrossVal builds and operates the core, ingestion and AI layer; the internal systems team owns bounded reporting and configuration; spokes are vendor-managed. |
| Steady state | The operating model after Stage 2 closes (from January 2027): the Group runs day-to-day and CrossVal supports under a defined model. |
| Sovereign stack | The regionally hosted infrastructure for the owned core: UAE preferred, with regional options, built sandbox-first so it can move between data centres without rework. |
| Hypercare | The period of intensive, rapid-response support immediately after go-live. |
| Origination vs onboarding | Origination is where a client relationship starts (mostly at M/HQ). Onboarding, the regulated intake and risk assessment, is performed separately by each entity for its own clients. |
The systems
| System | What it is |
|---|---|
| ViewPoint (VP) | The current entity-management system of record (on-premise, 2019 version; support ends within roughly 12 months). An upgraded version exists with a completed KYC360 API. |
| Quantios (QC) | The cloud trust-and-corporate-services platform assessed in Stage 1; a candidate spoke, not the system of record, in this design. |
| KYC360 (RiskScreen) | Screening and client-intake tool used by M/HQ and internal compliance, at onboarding and on an ongoing daily basis. |
| ComplyAdvantage | Screening tool used by Rethink and RAA for their own clients, and by the R&C function via the same internal instance. |
| Xero | Cloud accounting and invoicing used by Rethink and RAA today; the accounting spoke for Stage 2 is confirmed in the WS0 evaluation. |
| Inflo | RAA's audit execution and document tool. |
| BlueSky | The Group's HR management system. |
| AI assistants | The assistant layer for extraction, drafting and summarisation. Candidates include Microsoft Co-pilot (inside M365) and Anthropic's Claude; the platform choice is made in Stage 2 once the prompt libraries and usage policies are proven. Governed, human-reviewed, never the system of record. |
Acronyms
| Acronym | Meaning |
|---|---|
| ADGM | Abu Dhabi Global Market, a UAE financial free zone and regulator the Group files into. |
| AEOI | Automatic Exchange of Information: the FATCA and CRS reporting regimes. |
| BAU | Business as usual: day-to-day changes (for example ownership or control changes arriving by email) outside onboarding and periodic review. |
| CDD | Client due diligence: the identity and risk information collected on a client. |
| CRA | Client risk assessment: the ViewPoint workflow that scores risk and auto-assigns review dates. |
| CRS | Common Reporting Standard, the OECD tax-information exchange regime. |
| CSP | Corporate services provider. |
| CT / VAT | UAE corporate tax / value added tax. |
| DIFC | Dubai International Financial Centre, a UAE financial free zone and regulator the Group files into. |
| DP | Data protection. |
| FATCA | The US Foreign Account Tax Compliance Act. |
| FTA | The UAE Federal Tax Authority. |
| FTE | Full-time equivalent. |
| KPI | Key performance indicator. |
| KYC | Know your client: the regulated identity and screening obligations. |
| MF ID | Master-file identifier: the unique party ID enforced in ViewPoint at M/HQ. |
| MLRO | Money Laundering Reporting Officer: the named officer in each entity who owns onboarding and AML compliance. |
| OCR | Optical character recognition: machine-reading documents into structured data. |
| PO | Purchase order. |
| RAID | The risks, assumptions, issues and dependencies log kept through delivery. |
| R&C | Regulatory and Compliance: Rethink's outsourced compliance service line, serving external clients (distinct from the Group's internal compliance). |
| SME | Subject-matter expert. |
| UAT | User acceptance testing: the function heads' sign-off that the build works. |
| UBO | Ultimate beneficial owner. |
End of proposal. Prepared by CrossVal for the M/HQ Group. The next step is the review conversation in Section 15.