Independent financial-risk advisors who are engaged on regulatory-capital and supervisory matters are, at Tier-1 banks, engaged by the Board. Every Non-Executive Director we have worked with has, before signature, asked a version of the same five questions. This page answers them in the order they are asked: independence, conflicts, partner bios, professional indemnity cover, and the reference process. Everything here is on the record, in writing, and the responsibility of the Managing Partner.
Independence in financial-risk advisory is a small-boutique question dressed up as a Big-4 question. At scale, it is nearly impossible to hold; at boutique scale, it is the only thing we sell. The answers below are the architecture. If any one of them changes, the Board will be notified in writing before the next mandate signature.
What this unlocks. Because Ezelman does not hold an audit practice, does not sell software, and does not take placement economics, the senior advisory opinion presented to the Risk Committee is free of the commercial incentives that systematically distort the advice Boards receive from larger firms. This is not a marketing point. It is the operating constraint of the firm.
At large firms, the conflict check is a compliance step at the end of a sales cycle. At Ezelman it is the first conversation, on the first call. The rules below are the ones the Managing Partner applies before a proposal is written — not after it is signed.
The declaration lists: prior employment with the client (none undisclosed), prior employment with the client’s supervisor, prior employment with peer institutions in the same market, ownership interests in any counterparty, immediate-family interests at the client, and any ongoing personal consulting relationship outside the Ezelman roster. The declaration is renewed annually, on each new mandate, and on any change in personal circumstances.
Where a declaration would otherwise be blank for formality’s sake, we note explicitly that it is blank. An empty conflicts page is the answer. A conflicts page that says “none known” without a declaration underneath it is not.
Ezelman operates a partner-led model. Every mandate has a named partner signing the engagement letter, chairing the steering committee, and presenting to the Board where required. No mandate is delegated to a junior team supervised at distance. The bios below are the senior leadership the Risk Committee will encounter.
Hannan Mohammad is the founder and Managing Partner of Ezelman. Before founding the firm in 2020, he spent eighteen years inside European Global Systemically Important Banks, leading CRR3 implementation programmes, ECB on-site inspection responses, supervisory stress-testing exercises and regulatory-transformation mandates across credit-risk, counterparty-risk and Pillar 2 domains.
He chairs every Ezelman engagement in Europe directly, signs every engagement letter, and is the named partner on every credit-risk OSI, Pillar 2G defence and CRR3 implementation mandate the firm holds. He is the Board’s point of contact.
The Ezelman senior roster is a closed population of directors, senior managers and former supervisors with a minimum of fifteen years of in-bank regulatory experience. We do not staff mandates with junior consultants supervised at distance. The minimum hiring seniority at Ezelman is Director — this is a standing firm policy and is stated explicitly on the Careers page.
Named senior roster for any given mandate is disclosed to the Risk Committee before signature. CVs, supervisory references and personal conflicts declarations for every named senior are provided on request. Where the mandate involves specialist disciplines (model validation for IRB, ICAAP documentation, ORSA, IFRS 9) the senior leading that stream is named in the engagement letter and attends every steering committee in person.
Ezelman carries professional indemnity and civil liability insurance calibrated to the typical mandate size and the plausible downside of a senior regulatory-advisory engagement at a G-SIB. The policy is not decorative. A certificate of insurance is produced, unredacted, to the General Counsel of every client at contract signature and is renewable annually.
Ezelman’s standard engagement letter caps contractual liability at three times the mandate fee, with the uncapped carve-outs that are customary in senior regulatory advisory: fraud, wilful misconduct, breach of confidentiality and breach of data protection law. We do not request uncapped liability in our own favour; we do not accept uncapped liability running the other direction either.
Every Ezelman engagement letter contains a walk-away clause: where the client instructs the firm to advance a position the Managing Partner judges incompatible with the applicable supervisory framework or professional standards, Ezelman reserves the right to resign the mandate on written notice with no further fee, rather than document a position we do not hold. This clause is not negotiable in either direction.
Every new Board engagement at Ezelman runs through the same five-step reference process. The process is designed to put the Risk Committee Chair in direct contact with two peer Chairs Ezelman has worked for, before any engagement letter is signed. The process is not reversible — we will not compress it, and we will not skip step three.
On peer-chair references specifically. The two peer Chairs Ezelman will introduce are always currently or recently serving Non-Executive Directors at peer institutions in a comparable jurisdiction. Where the Risk Committee would prefer a reference from a more specific angle — a former Head of Risk, a former JST coordinator, a serving CRO — that is accommodated on request. The reference introductions are never paid for, scripted or moderated.
The five disclosures on this page are consolidated in a single governance pack: independence letter, conflicts register, partner bios, PI certificate, standard engagement letter with walk-away clause, and the reference-process SLA. The pack is produced to the Board Secretary on request and is renewable annually. No NDA required to receive it.