Financial Crime Risk Management

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Regulator Readyness

The Financial Conduct Authority ('FCA') uses a variety of tools to monitor whether an authorised firm is in compliance with regulatory requirements - SUP 1A.4.

The FCA tool-kit includes desk-based reviews, on-site inspections and using skilled persons' - often issuing the firm to be reviewed with detailed pre-visit information requests.

We support clients to collate responsive information, prepare appropriate records, provide information requested by the regulator or skilled person, and to identify risk/omission in information provided.


The FCA Systematic Anti-Money Laundering Programme (‘SAMLP’) is used to test compliance with legal and regulatory requirements, to prevent and reduce financial crime.

The FCA also uses a programme of regular AML inspections for firms which present higher financial crime risk. These may be broad-based, thematic or targeted in their scope.

We assist clients to: (i) co-ordinate programme activity; (ii) ensure appropriate internal awareness; and (iii) maintain an open and transparent relationship with the regulator.


The FCA can require a firm to appoint a skilled person to collect information, conduct a review and produce a report for the regulator's use, on any area of potential regulatory interest or concern.

A firm must provide all reasonable assistance to a skilled person appointed under section 166 of the Financial Services and Markets Act (as amended by The Financial Services Act 2012).

SAMLP and skilled person reviews can be a severe drain on senior management time, and also impact staff in first and second line roles. We can help reduce the burden and operational impact.


Our Services
Help with the 'exam question'

FCRM assists clients to identify and where necessary clarify, information sought by the regulator, to ensure the correct exam question is reponded to, with audit trail/traceability maintained between requests received and information provided.

Useful links
FCA Skilled Person Reviews
SUP 1A.4

FCA Policy on Skilled Persons

Regulated Firm Duties (s166 review)

FCA Skilled Person Panel

FCRM Advisory Services