S166 Skilled Person

The review can be intensive and intrusive, involving a wide-ranging review of the firm’s financial crime controls, covering firm-wide governance arrangements through to detailed analysis of customer files and alert decisioning.

Its consequences can be wide and challenging for a firm, not to mention extremely costly, so it’s important that the right skilled person is selected at the outset.

We understand that all firms’ business activity, customer base and risk appetite will differ. We therefore work closely with our clients to develop a deep understanding of their business and FCC framework in order to apply an effective, proportionate and risk based approach to our S166 or independent reviews.

Plenitude's Role

Plenitude are appointed to the Skilled Person Panel for Lot E: Financial Crime. As defined by the FCA, this highlights our proven expertise on:

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 governance of these areas.

Whether you need Plenitude to act as your Skilled Person or support you through the Skilled Person / S166 review, we’re here to help.

Independent Assessment or Audit

Independent assessment or audit of your existing FCC framework to proactively identify potential control gaps or weaknesses.
Remediation / Response Plan

Development of your remediation or response plan to effectively address regulatory feedback or feedback from an S166 Review.
S166 Support Firm Side

Provide advice and support to successfully navigate an S166 review, including documentation reviews, training and awareness activities ahead of walkthroughs and staff interviews.
Transformation and Remediation Support

Work with you to implement the required enhancements as part of a remediation project or programme of work.