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Financial Crime Solutions

Financial Crime Solutions

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UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) - Skilled Person Reviews (s166)

Our s166 Capabilities

We have been appointed to the following lots on the FCA and PRA Skilled Person Panel with effect from 1 April 2022: 

Controls and Risk Management Frameworks (Lot C)

  • We provide advice, skills and technical expertise in assessing whether firms have effective controls and risk management frameworks, including identification and control arrangements to identify and mitigate risks in their business models (including outsourcing arrangements).
  • We specialise in the development and assessment of a risk-based approach to deliver fair outcomes for customers and operational resilience. 

Financial Crime (Lot E)

  • We provide advice, skills, and technical expertise in financial crime, anti-money laundering, anti-bribery and corruption, sanctions, cryptocurrency and payments solutions, tax evasion, market abuse (including insider dealing and market manipulation), and the adequate and effective governance of these areas.
  • We specialise in assessing the adequacy of firms’ financial crime compliance systems and controls.

Our appointment to the Skilled Persons Panel complements the financial crime investigations and risk advisory work we already perform for firms of all sizes, across the globe. We regularly work with firms to identify, address and prevent issues that can lead to regulatory interventions, such as a s166 review.

Key reasons why we are suited to help you

The consequences of a s166 review can be serious and there may be several stages of review and remediation during a skilled person review, leading to a significant demand on your in-house resources and management time. Guidehouse is well suited to act as your skilled person review:

  1. Proportionality - We believe that your risk and control framework should be proportionate to the nature, scale and complexity of your unique business. As such, our approach when conducting s166 reviews is rooted in proportionality, focusing on delivering practical recommendations that can be implemented. We will prioritise our recommendations to help you manage your risk.
  2. Independence - We work openly and transparently with the firm and the regulator, maintaining our independence throughout the review. We operate a no-surprise approach by having regular communication with you throughout the review.
  3. Subject Matter Expertise - Our team is experienced in performing cost effective s166 reviews as well as being deep subject matter experts. we have worked with global financial institutions, overseas banks in the UK and fintechs to build effective and efficient risk management and compliance programmes. Our team consists of former regulators, compliance officers, industry experts and consultants. We leverage our combined experience to conquer challenges from financial compliance to global investigations and enforcement.

Whether you are anticipating, facing, or preparing for, a s166 skilled person review, our team is ready to be your trusted advisor through the process. Please contact one of our specialists to discuss your requirements.

If you already have appointed a Skilled Person, we can provide advice and assistance before, during and after  the process as part of a separate firm-side engagement. In this capacity, we can assist you to prepare for a skilled person review, provide support to enable an efficient and effective review, perform remedial work based on recommendations by the skilled person, or perform “shadow” s166 reviews.

What is a skilled person review?

A skilled person review is an independent review of specific aspects of a regulated firm's activities, performed by a “skilled person”, and directed by the regulator. It is one of the supervisory tools that the FCA and the PRA can use under s166 of the Financial Services and Markets Act (FSMA). The regulator can appoint the skilled person directly, or require the firm to appoint a skilled person, to obtain a view and produce a report on specified matters. 

These reviews vary in nature and can cover any aspect of the firm’s business including assessments of the adequacy and effectiveness of a firm’s control and risk management frameworks, testing the application of policies and procedures, confirming that remedial work has been implemented, or collecting, analysing and verifying information regarding specific areas of concern within a firm. 

What triggers a s166 review?

A s166 review can be triggered by regular supervision activity, a thematic review or other reasons, such as a crystallised event.

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