The Compliance Doctor

A Section 166 skilled person review is one of the most significant regulatory interventions an FCA-regulated firm can face. It is not a routine supervisory visit. It is a deep, independent examination of your firm's systems and controls — commissioned by the regulator, paid for by you, and with findings that go directly back to the FCA.

The power to require a skilled person review sits within Section 166 of the Financial Services and Markets Act 2000, and the FCA uses it when it has concerns serious enough to warrant independent scrutiny. That might follow a supervisory visit, a whistleblower report, a significant operational failure, or a pattern of regulatory returns that has attracted attention. Whatever the trigger, the message is the same: the FCA does not believe it has sufficient visibility of what is happening inside your firm — and it intends to find out.

In this episode, we examine what a Section 166 review actually involves, how firms should prepare, and why the difference between a firm that navigates the process well and one that does not almost always comes down to preparation, documentation, and cultural readiness.

Whether you are a compliance officer, an MLRO, a senior manager with regulatory accountability under SMCR, or a board member facing your first s166 notification, this episode gives you the practical framework to understand the process and respond to it effectively.

We cover:

— What Section 166 actually is: the legal basis, when the FCA uses it, and what the notification means for your firm's regulatory relationship

— The skilled person appointment process: who gets appointed, how they operate, what their mandate covers, and the critical distinction between acting for the FCA and advising your firm

— Immediate priorities on notification: the actions your compliance team, MLRO, and senior managers must take in the first days and weeks

— Document and evidence readiness: what skilled persons typically examine, how to ensure your records, policies, and MI reflect actual practice, and why inconsistency across documentation is one of the most damaging findings

— Individual accountability under SMCR: how the review process intersects with Senior Manager accountability, what examiners expect from named function holders, and the personal risk that attaches to inadequate responses

— Common subject areas: financial crime controls, AML governance, Consumer Duty implementation, complaints handling, operational resilience, and culture and governance arrangements

— Managing the review itself: how to engage constructively with the skilled person, handle information requests efficiently, and avoid responses that expand the scope of examination unnecessarily

— Interpreting and responding to findings: how to approach the remediation plan, demonstrate genuine commitment to improvement, and use the process to rebuild regulatory confidence

This episode is essential listening if your firm:

— Has received or is anticipating a Section 166 notification

— Has recently undergone an FCA supervisory visit with outcomes that raised regulatory concern

— Has significant gaps in its compliance documentation, governance records, or management information

— Wants to understand the s166 process before it becomes an immediate operational reality

Resources mentioned in this episode:

Compliance Consultant's Section 166 Skilled Person Review Preparation Toolkit is a comprehensive, ready-to-use resource for FCA-regulated firms. It provides a structured preparation framework, document readiness checklists, individual briefing guides for senior managers, and remediation planning templates — everything your firm needs to engage with the s166 process in an organised, evidenced, and credible manner.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

Sanctions compliance is no longer a back-office checkbox. With OFSI issuing significant monetary penalties, the FCA embedding sanctions risk into its supervisory framework, and the geopolitical landscape producing new designations at pace, the consequences of inadequate screening have never been more immediate — or more personal.

The UK sanctions regime, administered through OFSI and underpinned by the Sanctions and Anti-Money Laundering Act 2018, creates strict liability obligations for regulated firms. Unlike many areas of financial regulation, intent is not always a defence. If your firm processes a transaction for a designated person, the question regulators will ask is not whether you meant to — but whether your screening procedures were adequate to prevent it.

In this episode, we examine what genuinely robust sanctions screening looks like, how your escalation procedures should function when a potential match is identified, and why firms most exposed are often those that have a screening system in place but have never stress-tested the procedures surrounding it.

Whether you are a compliance officer, an MLRO, or a senior manager with financial crime accountability under SMCR, this episode gives you the practical framework to assess whether your sanctions procedures are fit for the current regulatory environment.

We cover:

— The UK sanctions framework: OFSI's role, the Sanctions and Anti-Money Laundering Act 2018, and how FCA supervisory expectations interact with the OFSI licensing and reporting regime

— What adequate screening requires: customer screening, transaction screening, and the ongoing monitoring obligations many firms systematically underestimate

— Screening system calibration: why matching rules, threshold settings, and watchlist coverage matter as much as the system itself — and how poor calibration creates both false comfort and operational paralysis

— Escalation procedures: what must happen when a potential match is identified, who is responsible at each stage, and how the decision-making process must be documented

— OFSI reporting obligations: when you must report, what the report must contain, and the personal liability that attaches to failure under the strict liability regime

— Correspondent and payment chain risk: how sanctions exposure travels through payment chains and what your procedures must do to address indirect exposure

— SMCR accountability: how sanctions failures are attributed to named Senior Managers and why documented escalation trails are not optional

— Keeping pace with designations: how to ensure procedures reflect new designations promptly and how to evidence that your watchlists are current

This episode is essential listening if your firm:

— Has a screening system but no documented escalation procedures for handling potential matches

— Has not reviewed its sanctions procedures since the introduction of Russia-related designations

— Is preparing for an FCA supervisory visit, s166 review, or internal financial crime audit

— Has identified potential matches that were not escalated or reported in line with OFSI requirements

Resources mentioned in this episode:

Compliance Consultant's Sanctions Screening Procedures & Escalation Playbook is a ready-to-use toolkit for FCA-regulated firms. It provides a structured screening framework, step-by-step escalation procedures, decision-making templates, and OFSI reporting guidance — everything your firm needs to manage sanctions risk to a standard that reflects current regulatory and enforcement expectations.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

Every FCA-regulated firm and payment service provider subject to the Money Laundering Regulations 2017 must have a Business-Wide Risk Assessment. Not a summary. Not a policy statement. A documented, evidenced, and regularly reviewed assessment of the specific money laundering and terrorist financing risks your firm faces — and what it is doing about them.

The Business-Wide Risk Assessment is the cornerstone of your entire AML framework. It informs your policies and procedures, shapes your customer risk appetite, and tells your regulator whether you genuinely understand the financial crime risks inherent in your business model. When built properly, it is one of the most powerful demonstrations of AML competence. When built poorly — vague, generic, or disconnected from actual business activity — it is one of the first things a skilled person examiner will use to evidence a systemic failure of your financial crime controls.

In this episode, we examine what a genuinely robust Business-Wide AML Risk Assessment looks like, what the MLRs 2017 require it to contain, and why so many firms are carrying significantly more regulatory risk in this area than they realise.

Whether you are an MLRO, a compliance officer, or a senior manager with AML accountability under SMCR, this episode gives you the practical framework to assess whether your Business-Wide Risk Assessment is fit for regulatory scrutiny.

We cover:

— The regulatory requirement: Regulation 18 of the MLRs 2017, what it mandates, and how the FCA assesses compliance during supervisory visits and thematic reviews

— The factors your assessment must address: customer risk, product and service risk, geographic risk, delivery channel risk, and transaction risk — and why treating these in isolation produces an incomplete picture

— Using the National Risk Assessment: how the UK NRA should inform your firm-specific analysis and why simply referencing it is not sufficient

— Evidencing your assessment: what documentation regulators expect, how to demonstrate that risk ratings are based on analysis rather than assumption, and why generic assessments are immediately identifiable

— Connecting assessment to controls: how your Business-Wide Risk Assessment should drive your policies, procedures, customer risk appetite, and monitoring arrangements

— Review obligations: how frequently your assessment must be reviewed, what triggers an out-of-cycle update, and how to evidence it reflects your current business model

— MLRO ownership under SMCR: how personal accountability attaches to the Business-Wide Risk Assessment and what adequate discharge of that responsibility looks like

— Common failures: recurring weaknesses identified by the FCA, FATF, and OPBAS that your assessment should be specifically designed to avoid

This episode is essential listening if your firm:

— Has a Business-Wide Risk Assessment not substantively reviewed since the MLRs 2017 came into force or since your business model materially changed

— Has an assessment that describes risks generically rather than evidencing firm-specific analysis

— Is preparing for an FCA supervisory visit, s166 skilled person review, or internal AML audit

— Has recently expanded into new products, services, or markets not reflected in its current assessment

Resources mentioned in this episode:

Compliance Consultant's Business-Wide AML Risk Assessment Template is a ready-to-use toolkit for FCA-regulated firms and PSR-authorised payment service providers. It provides a structured assessment framework, risk factor scoring methodology, evidencing guidance, and governance templates enabling MLROs and compliance teams to build and maintain an assessment that genuinely reflects their firm's risk profile and satisfies current regulatory expectations.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

When a Senior Manager leaves a regulated firm, retires, or moves role, the accountability they carried does not simply transfer with their laptop and access credentials. Under SMCR, handover is a regulated event — and the documentation surrounding it is one of the most consistently underprepared areas of Senior Manager regime compliance.

The FCA is explicit. Senior Managers must take reasonable steps to ensure that any person who succeeds them in a Senior Management Function is appropriately briefed on the responsibilities, outstanding issues, and unresolved risks attached to that role. Where handover documentation is absent, inadequate, or produced as an afterthought, the consequences can attach to both the departing manager and those responsible for governance oversight.

In this episode, we examine what genuinely robust SMCR handover documentation looks like, what the FCA expects the process to achieve, and why firms consistently confuse process with substance in this area.

Whether you are a compliance officer, a departing Senior Manager, or a board member overseeing succession, this episode gives you the practical framework to ensure handover is handled correctly and to a standard the FCA would recognise as adequate.

We cover:

— The regulatory basis: what SMCR requires in relation to Senior Manager handovers and how it interacts with Statements of Responsibilities and the Management Responsibilities Map

— What adequate handover documentation must contain: outstanding regulatory commitments, live issues, unresolved risks, pending FCA correspondence, ongoing investigations, and the current state of key control frameworks

— The departing manager's obligations: what reasonable steps to ensure an adequate handover look like in practice and how personal liability can attach to a handover that is negligently inadequate

— The receiving manager's responsibilities: what due diligence a successor should conduct before accepting a Senior Management Function and how to document adequate briefing

— Governance oversight: the firm's obligations to facilitate the handover process and how documentation connects to your broader SMCR governance framework

— Timing and process: when handover documentation should be initiated and the common shortcuts that create regulatory gaps

— FCA notification interactions: how Senior Manager departures and appointments connect to regulatory notification obligations under SUP 10C and the required timelines

— Post-handover monitoring: how to evidence that the successor has assumed meaningful accountability rather than simply inherited a job title

This episode is essential listening if your firm:

— Has experienced Senior Manager departures handled through informal briefings rather than documented handover processes

— Has no standardised handover template embedded within its SMCR governance framework

— Is planning a Senior Manager succession, restructure, or appointment in the near term

— Is preparing for an FCA supervisory visit or internal audit of its SMCR implementation

Resources mentioned in this episode:

Compliance Consultant's SMCR Handover Documentation Template is a ready-to-use toolkit for FCA-regulated firms. It provides a structured handover framework, comprehensive documentation templates, regulatory notification checklists, and governance guidance enabling firms to manage Senior Manager transitions consistently and to a standard that reflects current FCA expectations.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

The FCA's expectations around vulnerable customers have never been more explicit. Under Consumer Duty, identifying, recording, and appropriately supporting customers in vulnerable circumstances is not a discretionary act of goodwill — it is a regulatory obligation with board-level accountability attached.

The FCA's Financial Lives survey consistently demonstrates that the majority of UK adults display at least one characteristic of vulnerability at some point. Yet supervisory findings reveal that most firms still lack the policies, staff training, and operational procedures needed to identify vulnerability reliably and adapt their service delivery meaningfully in response. Having a vulnerable customer policy is not the same as having one that works — and the regulator knows the difference.

In this episode, we examine what a genuinely effective Vulnerable Customer Policy and Procedures framework looks like, how it connects to your broader Consumer Duty obligations, and why firms that treat vulnerability as an edge case rather than a mainstream compliance priority are storing up significant regulatory exposure.

Whether you are a compliance officer, a customer outcomes lead, or a senior manager with Consumer Duty accountability under SMCR, this episode gives you the practical framework to assess whether your current approach is fit for regulatory scrutiny.

We cover:

— The regulatory foundation: Consumer Duty rules, Principle 12, the FCA's Consumer Vulnerability Guidance, and what the four outcome areas require firms to deliver for customers in vulnerable circumstances

— Defining vulnerability correctly: the FCA's four driver framework — health, life events, resilience, and capability — and why a narrow definition creates immediate gaps in your identification process

— Identification in practice: training frontline staff to recognise vulnerability indicators, asking sensitive questions appropriately, and recording vulnerability data consistently and in a GDPR-compliant manner

— Adapting your service: what reasonable adjustments look like across different product types, communication channels, and customer journeys — and how to document that adjustments have been made

— Complaints and vulnerability: how your RCA process should identify whether complaint patterns disproportionately affect customers in vulnerable circumstances

— Governance and oversight: how vulnerability data should feed into management information, board reporting, and your Consumer Duty annual assessment

— SMCR accountability: how personal liability attaches to Consumer Duty failures affecting vulnerable customers and who is in the frame when systemic weaknesses are identified

This episode is essential listening if your firm:

— Has a vulnerable customer policy not reviewed since Consumer Duty implementation

— Relies on customers self-identifying vulnerability without proactive identification procedures in place

— Has no consistent process for recording vulnerability across the customer journey

— Is preparing for an FCA supervisory visit or producing its Consumer Duty annual board report

Resources mentioned in this episode:

Compliance Consultant's Vulnerable Customer Policy & Procedures Playbook is a ready-to-use toolkit for FCA-regulated firms. It provides a structured policy framework, staff guidance, identification and recording procedures, and governance templates enabling compliance and customer outcomes teams to embed vulnerable customer support that genuinely reflects current FCA expectations under Consumer Duty.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

Under SMCR, the FCA's Conduct Rules apply to virtually every individual working in a regulated firm. When a potential breach is identified, what happens next is not a matter of internal discretion — it is a regulated process with statutory reporting obligations, personal accountability consequences, and an audit trail the FCA will scrutinise.

The Individual Conduct Rules set baseline standards of behaviour for all staff. The Senior Manager Conduct Rules go further, placing specific obligations on those with the greatest influence over a firm's culture and controls. When those rules are breached — or when a firm has reasonable grounds to suspect they may have been — the obligation to investigate promptly, thoroughly, and consistently is not optional. Neither is the obligation to report certain breaches to the FCA within the required timeframe.

In this episode, we examine what a genuinely robust Conduct Rules breach investigation looks like, what the reporting obligations require, and why firms that handle these situations inconsistently or without proper documentation are creating significant regulatory exposure for themselves and their senior managers.

Whether you are a compliance officer, an HR professional with regulatory responsibilities, or a senior manager with SMCR accountability, this episode gives you the practical framework to ensure your investigation process is structured, defensible, and compliant.

We cover:

— The regulatory framework: the FCA's Conduct Rules under SMCR, who they apply to, and what constitutes a breach at both Individual and Senior Manager level

— Identifying potential breaches: how to recognise conduct that may engage the Conduct Rules and the common situations that trigger an investigation obligation

— Investigation structure: how to scope, initiate, and manage an investigation in a way that is fair, thorough, consistent, and legally defensible

— Documentation standards: what records must be created at each stage and why an incomplete paper trail is as damaging as the breach itself

— FCA notification obligations: which breaches must be reported, within what timeframe, and what the report must contain to satisfy regulatory expectations

— The interaction with employment law: how Conduct Rules investigations sit alongside disciplinary procedures and why compliance and HR must work in concert

— Proportionality and consistency: how to calibrate investigation outcomes to the severity of the breach and why inconsistent treatment creates additional regulatory risk

— Post-investigation actions: remediation, control improvements, and how findings should feed into your broader governance and risk framework

— SMCR and the duty of responsibility: how the Conduct Rules interact with Senior Manager accountability and what adequate supervision of individuals beneath you actually requires

This episode is essential listening if your firm:

— Has no documented investigation procedure for potential Conduct Rules breaches

— Has managed conduct issues informally without a structured investigation or regulatory notification assessment

— Is unsure which breaches require FCA notification and within what timeframe

— Is preparing for an FCA supervisory visit or internal audit of its SMCR implementation

Resources mentioned in this episode:

Compliance Consultant's Conduct Rules Breach Investigation Toolkit is a ready-to-use resource for FCA-regulated firms. It provides a structured investigation framework, documentation templates, FCA notification guidance, and outcome recording tools enabling compliance teams to handle Conduct Rules breaches consistently and to a standard that reflects current regulatory expectations.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

If you're a Senior Manager, MLRO, or Compliance Officer working inside an FCA-authorised firm, you already know that SMCR isn't just a box-ticking exercise — it's a personal accountability regime with real criminal and civil consequences attached to your name.

But here's the uncomfortable truth: most firms are still operating with responsibilities maps that are vague, out of date, or simply copied from a template that was never properly tailored to their actual business model. That's not compliance. That's a liability waiting to surface.

In this episode, we break down exactly what a robust SMCR Responsibilities Mapping Playbook looks like, why it matters, and how to build one that will stand up to scrutiny — whether that's an internal audit, an FCA supervisory review, or a Section 166 skilled person report.

We cover:

— What the FCA actually expects to see in a Statements of Responsibilities (SoRs) and a Management Responsibilities Map (MRM), and where firms consistently fall short

— The most common gaps regulators identify during SMCR assessments, including overlapping accountabilities, unowned functions, and senior managers who can't articulate what they're personally responsible for

— How to align your responsibilities map with your governance framework, so it reflects how decisions are actually made — not how they look on paper

— The difference between prescribed responsibilities and inherent responsibilities, and why getting this wrong creates enforcement risk for individuals, not just the firm

— Practical steps for maintaining and updating your responsibilities map when people move, roles change, or your regulatory permissions are varied

— Why handover certificates matter more than most firms realise, and what needs to be in them to protect both outgoing and incoming Senior Managers

— How Certified Persons fit into your wider responsibilities framework, and the documentation you need to demonstrate ongoing fitness and propriety

We also look at real-world enforcement themes from the FCA's published Final Notices and supervisory statements, drawing out the practical lessons that should be shaping how your firm approaches individual accountability right now.

Whether you're preparing for an SM&CR audit, onboarding a new Senior Manager, or simply trying to get your house in order ahead of a period of regulatory change, this episode gives you a clear, actionable framework to work from.

Resources mentioned in this episode:

— FCA's SMCR webpage and Senior Managers Regime guidance: fca.org.uk

— FCA SYSC Sourcebook — Senior Management Arrangements, Systems and Controls

— The Compliance Playbook (free resource): https://bit.ly/CP202602A — a practical guide covering SMCR responsibilities mapping, AML risk assessments, operational resilience planning, and more. No email capture, no sales pitch — just useful content built by qualified regulatory consultants.

Subscribe, follow, and leave us a review — it helps more compliance professionals find content that actually makes a difference to how they work.

Got a topic you'd like us to cover? Get in touch via complianceconsultant.org or connect with us on LinkedIn at linkedin.com/company/compliance-consultant-uk

Compliance Consultant — Making Compliance Work.

Submitting a Senior Manager Function application to the FCA sounds straightforward. In practice, it's one of the most consequential regulatory processes a firm will go through — and one where mistakes, omissions, or poor preparation can result in delays, requests for further information, or in serious cases, outright rejection.

Under SMCR, every individual performing a Senior Manager Function must be approved by the FCA before they take up their role. That means your application needs to be complete, accurate, and compelling — demonstrating not just that the individual meets the fit and proper standard, but that your firm has the governance structures in place to support proper individual accountability.

In this episode, we walk through what a successful SMF submission actually involves, where firms consistently go wrong, and how to build a preparation process that gives your application the best possible chance of approval — first time.

We cover:

— The core components of an SMF application, including the Form A submission, Statements of Responsibilities, and the supporting governance documentation the FCA expects to see alongside them

— What the FCA's fit and proper assessment actually examines — honesty and integrity, competence and capability, and financial soundness — and how to evidence each dimension effectively

— The most common reasons SMF applications are delayed or returned, including gaps in the Statement of Responsibilities, insufficient explanation of the individual's scope of accountability, and inadequate disclosure of regulatory history

— How to prepare the candidate for the application process, including what they need to understand about their personal obligations before they sign their Statement of Responsibilities

— Criminal records, regulatory sanctions, and adverse financial history — how to handle disclosure properly and avoid the disclosure failures that draw immediate scrutiny

— The handover process — what documentation needs to be in place when an outgoing Senior Manager exits and an incoming one is approved, and why gaps here create significant regulatory risk

— Regulatory references and what your firm is required to disclose when another firm requests one for an SMF candidate — and the liability that comes with getting this wrong

— How to manage the approval timeline, including the FCA's standard assessment periods, how to handle acting-up arrangements lawfully, and when to seek pre-submission engagement with the regulator

Whether you're onboarding your first Senior Manager, replacing a departing SMF holder at short notice, or simply trying to make sure your firm's approval process is properly structured, this episode gives you a clear, practical framework to follow.

Resources mentioned in this episode:

— FCA Connect — the online portal for SMF applications: fca.org.uk/firms/authorisation/connect

— FCA FIT Sourcebook — Fit and Proper test for Approved Persons and Senior Managers

— SUP 10C — FCA Senior Managers Regime for FCA-authorised firms

— The Compliance Playbook (free resource): https://bit.ly/CP202602A — practical guidance on SMCR responsibilities mapping, AML risk assessments, operational resilience planning, and more. Built by qualified regulatory consultants. No email capture, no sales pitch.

Subscribe, follow, and leave a review — it helps more compliance professionals find content that reflects the reality of working inside FCA-regulated firms.

Have a topic you'd like covered? Visit complianceconsultant.org or connect on LinkedIn

Compliance Consultant — Making Compliance Work.

Replacement business is one of the oldest conduct risks in financial services — and one that continues to generate regulatory findings, redress requirements, and in serious cases, enforcement action. The FCA has been clear: recommending that a customer switches, transfers, or cancels an existing product in favour of a new one carries significant responsibility. That responsibility sits with the firm and the individuals who made the recommendation.

Yet despite years of supervisory focus and published guidance, many firms are still not running the checks they need to. Oversight frameworks are inconsistent, file reviews aren't capturing the right information, and commercial incentives are quietly undermining the objectivity that good advice demands.

In this episode, we walk through what a Replacement Business Health Check involves, why it matters under the current regulatory climate, and how to structure a review that gives your firm genuine assurance — not false comfort.

We cover:

— What the FCA means by replacement business, and why the definition is broader than many firms assume — covering pension transfers, investment switching, insurance replacements, and mortgage refinancing

— The conduct risks the regulator consistently identifies, including inadequate comparison of surrender values, insufficient documentation of client objectives, and failure to evidence that the replacement genuinely serves the customer's best interests

— How Consumer Duty has sharpened the regulatory lens on replacement business, and what the outcomes-focused framework means for evidencing suitability and value

— What a file-based review should actually examine — the specific data points, red flags, and documentation standards that distinguish a robust audit from a superficial compliance exercise

— How to design a management information framework that gives Senior Managers genuine visibility of replacement business volumes, trends, and outcomes before they become systemic problems

— Common weaknesses identified during FCA supervisory visits and Section 166 reviews, and the remediation steps firms are being required to take

— How to assess whether your current policies, training, and oversight controls are proportionate to the volume and complexity of replacement business your firm writes

We draw on FCA thematic review outputs, published Final Notices, and supervisory statements to ensure this episode reflects what the regulator is genuinely focused on right now.

Resources mentioned in this episode:

— FCA Thematic Reviews on Pension Transfers and Investment Switching: fca.org.uk

— COBS 9 and COBS 19 — Suitability and pension transfer rules

— FCA Consumer Duty — PS22/9

— The Compliance Playbook (free resource): https://bit.ly/CP202602A — practical guidance on SMCR responsibilities mapping, AML risk assessments, operational resilience, and more. Built by qualified regulatory consultants. No email capture, no sales pitch.

Subscribe, follow, and leave a review — it helps more compliance professionals access content grounded in real regulatory practice.

Have a topic you'd like covered? Visit complianceconsultant.org or connect on LinkedIn at linkedin.com/company/compliance-consultant-uk

Compliance Consultant — Making Compliance Work.

Outsourcing a function doesn't mean outsourcing the responsibility for it. That's one of the most important — and most frequently misunderstood — principles in FCA regulation. Yet every year, firms face supervisory scrutiny, remediation requirements, and in some cases enforcement action, precisely because their third-party oversight arrangements weren't fit for purpose.

Whether you're relying on a cloud-based technology provider, a third-party AML screening service, an appointed representative, or an outsourced compliance function, the FCA expects you to demonstrate that you remain in control. And demonstrating control requires more than a signed contract and an annual review meeting.

In this episode, we walk through what a genuinely effective Third-Party Oversight Toolkit looks like — the frameworks, the documentation, the governance structures, and the ongoing monitoring processes that regulators expect to see when they look under the bonnet.

We cover:

— Why the FCA's outsourcing and third-party risk expectations have intensified, and what the regulator's operational resilience framework means for firms that rely on external providers for important business services

— How to conduct a proper third-party risk assessment — what factors to consider, how to weight them, and how to document your rationale in a way that will survive scrutiny

— The key elements of a robust outsourcing register, and why most firms' registers are missing critical information that regulators specifically look for

— What your contracts and service level agreements actually need to include from a regulatory standpoint — and the clauses that are commonly absent

— How to structure an ongoing monitoring programme for your critical and important outsourced functions, including the metrics, triggers, and escalation routes you need to have in place

— The specific oversight expectations that apply to firms using appointed representatives under FSMA, and how the FCA's AR regime changes are reshaping principal firm responsibilities

— Exit planning — why you need a credible exit strategy for every material third-party arrangement, and what that documentation should contain

— How to embed third-party oversight into your broader governance framework, so it's genuinely owned at Senior Manager level rather than sitting in a spreadsheet nobody looks at

We draw on FCA Dear CEO letters, published supervisory findings, and thematic review outputs to ground this conversation in what the regulator is actually seeing across the market — and what it expects firms to do differently.

Third-party risk is increasingly a conduct and consumer outcomes issue, not just an operational one. If your customers could be harmed by the failure or poor performance of a provider you've engaged, that risk sits with you. This episode gives you the tools to manage it properly.

Resources mentioned in this episode:

— FCA Outsourcing and Operational Resilience guidance: fca.org.uk

— FCA PS21/3 — Strengthening appointed representatives regime

— SYSC 8 — Outsourcing requirements for common platform firms

— The Compliance Playbook (free resource): https://bit.ly/CP202602A — a practical guide covering SMCR responsibilities mapping, AML risk assessments, operational resilience planning, and more. Built by qualified regulatory consultants. No email capture, no sales pitch.

Follow us and leave a review — it helps more compliance professionals find practical, regulation-grounded content that makes a real difference to how their firms operate.

Want to suggest a topic or ask a question? Visit complianceconsultant.org or connect with us on LinkedIn at linkedin.com/company/compliance-consultant-uk

Compliance Consultant — Making Compliance Work.