The Regulator’s Last-Minute Demand
You are the project manager for a new data platform at a mid-sized bank. The project is in the final testing phase, with go-live scheduled in three weeks. The budget is 2.5M EUR, and 92% has been spent. The vendor has delivered all components, and your team is executing the acceptance test plan. Yesterday, a new compliance officer, hired after a recent regulatory audit, informed you that the platform must include a real-time fraud detection module that was not in the original scope. Without it, the platform cannot be certified for production. The vendor says they can add it, but it will take at least six weeks and cost an additional 300k EUR. Your sponsor is under pressure to show progress and is reluctant to delay go-live. The business users are eager to start using the platform.
1. Identify the key stakeholders and analyze their interests, influence, and potential impact on the project. What is your immediate course of action to address the compliance requirement?
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Key stakeholders: 1) Compliance officer – high influence (can block certification), interest in regulatory adherence. 2) Sponsor – high influence (budget approval), interest in meeting schedule and showing progress. 3) Vendor – medium influence (can deliver but at cost), interest in additional revenue and maintaining relationship. 4) Business users – low influence on decision but high interest in using the platform. 5) Regulator – external, high influence, interest in compliance. Immediate actions: 1) Convene a meeting with sponsor and compliance officer to clarify the requirement and confirm it is mandatory. 2) Assess impact on scope, schedule, and budget: six-week delay, 300k EUR overrun (12% of original budget). 3) Explore options: phased go-live with manual fraud checks until module is ready, or negotiate with vendor for faster delivery at higher cost. 4) Update risk register and communicate transparently with stakeholders. 5) Do not proceed without compliance sign-off, as it risks regulatory penalties and reputational damage.
2. The sponsor insists on going live as planned and adding the module later. How do you handle this conflict while maintaining project integrity and stakeholder trust?
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First, document the sponsor’s request and the associated risks in writing, including potential regulatory non-compliance. Then, facilitate a meeting with the sponsor and compliance officer to ensure the sponsor fully understands the legal and business consequences. Propose a compromise: go-live with a manual fraud detection process (if acceptable to compliance) and a clear plan to implement the automated module within an agreed timeframe. If compliance does not accept manual process, escalate to the project board or steering committee, presenting a decision paper with options, risks, and recommendations. Maintain transparency with the team and stakeholders about the decision and its rationale. This approach balances the sponsor’s desire for progress with the need for compliance, and demonstrates ethical leadership and stakeholder management.