Carl Hackman writes for the April edition of BUlletin.
22nd June 2025
CCICM’s director, Carl Hackman, contributed in The Berne Union’s BUlletin April 2025 edition writes about “Building a global collections network is less about chasing debts, and more about managing relationships, ethics, and risk”.
I often ask myself which is harder—herding squirrels or cats? The answer is that neither compares to the challenge of creating an international agent network.
For nearly 40 years, we have specialized in international debt collection. Over time, we have managed our own network and participated in others. However, maintaining consistent quality across a global network has proved to be a major challenge. The turning point for us came about ten years ago, when we were asked by a large UK government department to create an international network of collection agencies that met the standards of the UK Financial Conduct Authority. In this article, we share some of the challenges we encountered on that journey.
As you can imagine, convincing diverse companies with varying legal systems, commercial aspirations, management structures, resources, and most importantly levels of commitment to adhering to a regulatory regime that is not their own, is no easy task. On top of that, the culture of collections in many regions differs significantly from what we have come to expect in the UK over decades of practice.
In one European country, for example, violence has historically been a tool for debt collection—an unthinkable practice in the UK. In 2016, over a debt of just USD 53, a collector threw a firebomb into an apartment where a two-year-old child was sleeping. The child received severe burns. Following this outrageous attack, new legislation was introduced to remove violence from debt recovery, although its efficacy remains a subject of debate. In a 2020 case, collectors targeted a single mother for a debt incurred by her ex-husband. They harassed the family, threatened to kidnap the child, and seriously vandalized the property. Though the debt was eventually paid, the trauma the family endured is lasting. Sadly, this is not the only country where violent and unethical methods are utilized in collection; such practices are widespread in many regions.
With these quite extreme examples in mind, the importance of knowing who we are dealing with in an international network is clear. If we aim to deliver fair and ethical debt recovery, in accordance with Financial Conduct Authority rules, then that is what we must do. So where do we begin?
Firstly, it begins with due diligence regarding the partner. It is vital to conduct thorough research on the organization, including analyzing media coverage, submitting a KYC report, and even a credit report to ensure it is correctly and ethically submitting credit information. In some instances, it is viable to visit the partner’s office in person to understand their practice and begin establishing a working relationship.
When a partner is considered viable, it is important to conduct an onboarding process. We deploy a three-stage process. First, we conduct exhaustive due diligence and extensive questionnaires. Second, all research and responses are submitted to our compliance department for independent approval. Finally, we conduct both virtual and physical audits on all of our partners. These audits, which are expensive but absolutely necessary, continue over the duration of our relationship with our partner and are invaluable for the purposes of continued oversight.
After onboarding, ongoing oversight is critical to ensure the partner consistently adheres to best practices. In addition to auditing, we provide regular training to partners based on legislative changes, regulations, ethical and compliance standards. Additionally, incorporating case studies and real-life scenarios into training sessions can help partners understand the practical application of ethical practices. Regular assessments and feedback sessions can further reinforce learning and ensure continuous improvement. By implementing these comprehensive training strategies, organizations can ensure that their partners consistently adhere to the highest standards of ethical debt collection.
Performance monitoring can also help us understand how a partner works, areas of strength and weakness, and adherence to ethical standards, as can conducting surface-level due diligence checks such as social media, online reviews, and media screening. Following this, conducting an audit on the partner helps cover all bases regarding their practices, operations, and level of compliance.
Ultimately, nothing ensures compliance better than a team working hand in hand with clear communication, mutual respect, and a shared commitment to excellence. When every member understands its role and the importance of adhering to guidelines, the entire organization benefits. This collaborative approach not only provides positive engagement and partnership but also drives continuous improvement and innovation. By utilizing each team member’s strengths and maintaining open lines of communication, we can ensure that compliance is not just a word but a natural outcome of our daily operations.
Hosting networking events where partners can meet face to face is essential. These events foster deeper collaborative involvement within the network, ensuring that all members see each other not just as business contacts, but as integral parts of a supportive community. This personal interaction helps build trust, encourages the sharing of ideas, and strengthens professional relationships. By facilitating these connections, we create a more cohesive and dynamic network, ensuring the partnership can succeed.
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