S166 Skilled Person Services

Financial Crime Compliance

What is a Skilled Person/S166 Review?

Under the Financial Services and Markets Act 2000 (FSMA), the FCA’s Section 166 review is an independent review by a third party (a “skilled person”) about aspects of a regulated firm’s activities where the FCA has concerns or requires further analysis.

“Skilled person reviews are considered to be an effective regulatory tool and have a good record of mitigating risks to consumers.” – FCA Handbook

Section 166 reviews are typically 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.

The skilled person will assess the adequacy and effectiveness of the financial crime control environment. If an attestation has been completed, the skilled person may also seek to test whether the issue has been effectively remediated or implemented to meet UK regulatory standards, and in either case that no further gaps exist.

The consequence of a Skilled Person review can be wide and challenging for a firm, not to mention extremely costly. As a consequence, it is important that the right skilled person is selected at the outset.

For further details on what can trigger a Section 166 and the overall process, take a look at our recent Whitepaper on Managing the Risk of a Skilled Person Review.

Plenitude’s Role

Plenitude are appointed in to the Skilled Person panel for Lot E: Financial Crime. As defined by the FCA, the appointment 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 are here to help. We will not only bring our extensive experience and expertise to the engagement but will always act in a proportionate and pragmatic way to ensure you are able to deliver what is required.

How Can Plenitude Help?

Plenitude is a niche consultancy firm specialising in Financial Crime Risk and Compliance. Our focus is firmly on addressing the legal, regulatory, reputational and social imperative for financial institutions to take diligent and rigorous steps to mitigate financial crime risks.

Plenitude have also provided extensive support to firms to prepare them for supervisory visits (including SAMLP reviews) or S166 reviews as part of the upfront remediation effort or assisting the firm during the review. We have a deep understanding of regulatory expectations and are able to support our clients to assess their existing systems and controls, prepare them for the review; and implement the required control enhancements, in a proportionate and effective manner.

Plenitude’s Approach – Firm Side Support

  • An independent assessment of your existing Financial Crime Compliance (FCC) framework (including systems, controls and client files) to proactively identify potential control gaps or weaknesses
  • Strategic advice relating to your FCC strategy and establishing effective AML and Sanctions Programs
  • Development of your response plan to effectively address regulatory feedback and ensure you comply with your regulatory obligations
  • Transformation and remediation support to address regulatory feedback or address know gaps and weaknesses
  • Controls testing to establish the effectiveness of your current systems and controls

Our team of FCC  specialists have extensive experience assisting firms prepare for regulatory and Section 166 reviews, alongside development of action plans post feedback. Through this work we have developed an effective and structured approach that is anchored in UK laws, regulations and guidance and reflects FCA expectations and lessons learned from multiple engagements. We are also able to deploy a proven suite of assets and deliverables to expedite delivery and provide further assurance to the engagement, minimising the risks associated with regulatory reviews.

Our independent reviews can be conducted in short order and enable firms to proactively self-identify any issues ahead of a review by the FCA and to provide assurance to the board and senior management.

Get in Contact

We believe the depth of our FCC expertise and proven track record in assisting firms successfully navigate S166 and regulatory reviews, combined with our competitive rate card and innovation, differentiates us from our competitors.

We also operate with the highest levels of integrity and are honest and realistic about budgets, challenges and timeframes from the outset.  We frequently communicate with our clients on progress and about the best ways to maximise and allocate the budget, and the deployment of our team.