In the highly regulated environment of a FTSE 100 bank, a Group Chief Risk Officer (CRO) does not simply vanish overnight. When the person legally responsible for signing off on a £30 billion bank’s internal controls leaves with zero notice, it is not a standard “resignation”—it is a forensic red flag signaling an unmitigated internal crisis. See our article here.
On 15 January 2026, Keiran Foad (see above) stepped down as Group Chief Risk Officer of NatWest and left the bank immediately. The bank’s PR machinery framed this as a routine departure. However, the regulatory footprint tells a completely different story.
To prove that Foad’s sudden exit was a “Dirty Withdrawal,” we only need to look at how NatWest handled the departure of his direct predecessor.
The Baseline of Normal: Bruce Fletcher (2022–2023)
When a tier-one bank changes its risk leadership under healthy conditions, it is a highly choreographed event designed to reassure the markets and the Financial Conduct Authority (FCA).
When former CRO Bruce Fletcher left NatWest, the process was textbook:
- The Announcement: NatWest issued a Regulatory News Service (RNS) alert on 1 December 2022, announcing Fletcher would be retiring “next year.”
- The Handover: The bank named his permanent successor (Keiran Foad) in the exact same announcement, stating Foad would join in Q2 2023.
- The Register: Fletcher remained “Active” on the FCA Register for months, allowing for a smooth transition of the bank’s Management Responsibilities Map.
This is how a bank manages a “Fit and Proper” executive transition.
The Anomaly: Keiran Foad (January 2026)
Compare that 6-month, highly controlled handover to what happened to Keiran Foad:
| Metric | The “Normal” Transition (Fletcher) | The “Crisis” Exit (Foad) |
| Notice Period | 6 Months | 0 Days |
| Successor Status | Named 6 months in advance. | No successor. “Search commencing now.” |
| Interim Required? | No. Direct handover. | Yes. Sean Pilcher forced to step in immediately. |
| Corporate Messaging | “Retiring next year.” | “Stepped down… and has left the bank.” |
| FCA Register Status | Active during handover. | Hard Stop End Date: 15 Jan 2026. |
A bank does not lose its Chief Risk Officer with zero notice, forcing an interim operational officer to step in overnight, unless the risk they are managing has become too toxic to hold.
The Regulatory Trap: Hiding Behind Form C
Under the Senior Managers and Certification Regime (SM&CR), the true story of Foad’s departure is locked inside a confidential document known as Form C (Notice of ceasing to perform a controlled function), which NatWest had to file with the FCA within 7 days of his exit.
While the public cannot see this form, the NatWest Board is legally bound by what they submitted. The critical vulnerability lies in Section 5: Fitness & Propriety.
The fact that Foad executed an emergency eject on 15 January proves which path the risk had taken.
The Challenge to the Board
The secrecy of an FCA Form C is not a shield for corporate misconduct. The NatWest Board, and the current Interim CRO Sean Pilcher, inherited the exact liability that Foad left behind.
We challenge the Board to answer: Did the Form C filed for Keiran Foad accurately disclose the hundreds of risk alerts sent to his office prior to his sudden departure? If not, the public FCA Register is currently hosting a fiction, and the “Dirty Withdrawal” is complete.
As Nikhil Rathi (see below), Chief Executive of the Financial Conduct Authority (FCA), champions his 2026 mandate of “market integrity” and strict executive accountability, we are forced to ask for his direct view on a glaring anomaly sitting inside his own database. We encourage him to read the latest case study update and read the case study page.
He is already aware though, having read an email on the case study in July 2025:
Resident Safety Optional?
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