The Compliance Doctor

The appointed representative regime was designed to widen access to regulated markets. But for principal firms, it comes with a burden of responsibility that many have consistently underestimated — and that the FCA has spent the last several years making significantly harder to ignore.Following its thematic review and the sweeping changes introduced under PS21/3, the regulator has made clear that principal firms are fully accountable for the conduct, competence, and compliance of every AR they appoint. If your AR causes consumer harm, mis-sells a product, or breaches regulatory requirements, the consequences land with you — not just with them. That reality demands a policy and oversight framework that is genuinely fit for purpose.In this episode, we walk through what a robust Appointed Representative Policy and Playbook looks like, why so many principal firms are still exposed, and how to build an oversight structure that satisfies regulatory expectations and protects your firm.We cover:— What the FCA's reforms to the AR regime actually require of principal firms, and the specific due diligence, oversight, and reporting obligations that came into force following PS21/3— How to structure an AR appointment process that assesses fitness and propriety, business model viability, and regulatory risk before onboarding — not after problems emerge— What your Appointed Representative Policy needs to contain, including governance responsibilities, monitoring frameworks, escalation procedures, and exit arrangements— The ongoing oversight programme your firm needs to operate — how frequently to review AR activity, what management information to collect, and what triggers should prompt enhanced supervision or termination— How to evidence that your ARs are operating within the scope of your permission and not straying into regulated activities you haven't authorised or don't hold permissions for— Consumer Duty implications for principal firms — how the outcomes-focused framework applies across your AR network and what you need to do to demonstrate that customers are receiving good outcomes regardless of which entity they're dealing with— Common failings identified by the FCA in thematic reviews of principal firm oversight, and the remediation steps firms have been required to take— When and how to terminate an AR relationship — the process, the documentation, the regulatory notification requirements, and how to manage the transition to protect customersWhether you oversee a single AR or manage a large network, the regulatory expectations are the same. This episode gives you a clear, practical playbook to meet them.Resources mentioned in this episode:— FCA PS21/3 — Strengthening the appointed representatives regime— FCA AR Regime Thematic Review findings: fca.org.uk— SUP 12 — Appointed Representatives sourcebookThe 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 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-ukCompliance Consultant — Making Compliance Work.

Consumer Duty has been in force since July 2023, and the FCA is no longer giving firms the benefit of the doubt. Supervisory visits, thematic reviews, and enforcement activity are all signalling the same message — having a Consumer Duty policy isn't enough. You need to evidence that your firm is consistently delivering good outcomes for retail customers, and that your board is sighted on the data that proves it.In this episode, we're talking about the Consumer Duty Toolkit — what it contains, why a structured, ready-to-use framework is the most efficient way to embed the Duty properly across your firm, and what the FCA actually expects to see when it comes looking.What we cover in this episode:We start with the four outcomes at the heart of Consumer Duty — products and services, price and value, consumer understanding, and consumer support — and why firms that treat these as four separate compliance workstreams consistently struggle to demonstrate the joined-up, outcome-focused thinking the FCA is looking for.We then look at what genuine embedding looks like in practice — the management information frameworks, the board reporting structures, the customer journey mapping, the complaints and feedback analysis, and the vulnerability identification processes that together give your firm a defensible evidence base.We discuss the Consumer Duty Annual Board Report — one of the most important documents your firm will produce each year and one that is still being significantly underestimated by many smaller authorised firms. We cover what it needs to contain, how it should be structured, and the common gaps that leave firms exposed.We also address the ongoing monitoring obligation — because Consumer Duty isn't a one-time implementation project. It's a continuous cycle of outcome testing, data review, and remediation, and firms that haven't built that cycle into their compliance monitoring programme are accumulating regulatory risk with every passing quarter.Why this matters right now:The FCA has been explicit that its Consumer Duty supervisory work is moving from implementation assessment to outcomes scrutiny. Firms that were given time to embed the Duty are now expected to demonstrate it is working. The regulator has already written to firms in multiple sectors where its data suggests consumer outcomes are falling short, and formal action is following in cases where firms cannot evidence their position.The stakes are significant. Consumer Duty failures can trigger requirements to withdraw products, remediate customers, and in serious cases result in public censure or financial penalties. Senior managers with board-level accountability for Consumer Duty outcomes face personal exposure where oversight has been inadequate.The practical takeaway:By the end of this episode, you'll have a clear picture of what a robust Consumer Duty framework looks like, where the most common gaps are, and how a structured toolkit can help your firm move from superficial compliance to genuine, evidenced good outcomes.Our Consumer Duty Toolkit is available to download at complianceconsultant.org — built by qualified regulatory consultants who understand exactly what the FCA expects, and ready to implement across your firm immediately.Who this episode is for:Essential listening for compliance officers, MLROs, customer experience leads, product owners, and any senior manager or NED with Consumer Duty accountability at an FCA-authorised firm.Compliance Consultant — Making Compliance Work.Visit us at complianceconsultant.org or call us on 0800 689 0190.References: FCA Consumer Duty — Finalised Guidance FG22/5; FCA Consumer Duty — Annual Review Requirements; PS22/9 A New Consumer Duty — Policy Statement; FCA Consumer Duty Implementation Review, 2024; Financial Services and Markets Act 2023.

When it comes to Politically Exposed Persons and high-risk customers, the gap between having an EDD process and having one that actually works is wider than most firms realise — and the FCA knows it.Enhanced Due Diligence is one of the most scrutinised areas of AML compliance in UK financial services. The Money Laundering Regulations 2017 are explicit: certain customers require a materially higher standard of scrutiny, documented evidence, and ongoing monitoring. Yet supervisory findings, enforcement actions, and thematic reviews consistently reveal the same failures — inadequate identification of PEPs, superficial risk assessments, absent senior management approval, and monitoring arrangements that exist on paper but deliver nothing in practice.In this episode, we go beyond the basics and examine what genuinely robust Enhanced Due Diligence looks like for PEPs and other high-risk customer categories. 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 current approach would withstand regulatory scrutiny.We cover:— The legal foundation: what the MLRs 2017 require for EDD and where FCA expectations go further than the minimum statutory standard— Defining PEPs correctly: domestic versus foreign PEPs, the scope of family members and known close associates, and the common categorisation errors that create immediate regulatory exposure— Why PEP status does not automatically mean refusal — and how to document a risk-based decision to onboard, decline, or exit a PEP relationship in a way that is fully defensible— The EDD factors your workbook must capture: source of wealth, source of funds, nature of the business relationship, geographic risk, transaction profile, and adverse media findings— Senior management approval requirements: who approves what, how that approval must be evidenced, and the governance trail regulators will look for— Ongoing monitoring obligations: what "enhanced" monitoring means in practice, review frequency, and what should trigger an out-of-cycle reassessment— The role of adverse media screening — why it is not optional and how to document your findings and decisions adequately— Common EDD failures identified by the FCA and FATF, and how personal liability under SMCR applies when those failures are traced back to named individualsThis episode is essential listening if your firm:— Has not reviewed its PEP and high-risk customer EDD procedures since the MLRs 2017 amendments— Is preparing for an FCA supervisory visit, s166 skilled person review, or internal audit— Has onboarded PEP relationships without a clearly documented, senior management-approved rationale— Has not stress-tested its ongoing monitoring arrangements against actual transaction activityResources mentioned in this episode:Compliance Consultant's PEP & High-Risk Customer Enhanced Due Diligence Workbook is a comprehensive, ready-to-use toolkit built for FCA-regulated firms and PSR-authorised payment service providers. It provides a structured EDD framework, fully formatted assessment workbook, and step-by-step guidance enabling compliance teams to complete, document, and evidence their EDD obligations to a standard that reflects current FCA and FATF expectations.Built by qualified regulatory consultants who know exactly what "good" looks like — because they have seen what the alternative costs.Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

The FCA and PRA's operational resilience framework is no longer a future obligation. The March 2025 implementation deadline has passed — and firms are now expected to be operating within their impact tolerances, not still mapping them.Operational resilience has moved from policy commitment to supervisory reality. Regulators expect firms to have identified their important business services, set meaningful impact tolerances, tested their ability to remain within those tolerances under severe but plausible disruption scenarios, and produced the self-assessment documentation to evidence it all. For many firms, the uncomfortable truth is that their self-assessment exists in name only — and a supervisory visit or operational incident would expose that quickly.In this episode, we examine what a genuinely robust Operational Resilience Self-Assessment looks like, what the regulators are expecting to find, and why the firms most at risk are those that treat this as a documentation exercise rather than a genuine test of their ability to withstand disruption.Whether you are a compliance officer, a chief operating officer, a risk manager, or a senior manager with operational resilience accountability under SMCR, this episode gives you the practical framework to assess whether your self-assessment would stand up to scrutiny.We cover:— The regulatory foundation: PS21/3, the FCA and PRA's joint policy statement, and what the supervisory expectations look like now the implementation deadline has passed— Identifying important business services correctly: the common scoping errors that leave firms exposed and how to apply the customer harm lens the regulators expect— Setting impact tolerances that are meaningful: why vague or untested tolerances are worse than none, and how to express tolerances in terms regulators and boards can interrogate— Mapping and testing: what scenario testing must demonstrate, how to document the results, and what constitutes adequate evidence that your firm can remain within tolerance— The self-assessment document itself: what it must contain, how it should be structured, and the governance sign-off requirements that sit behind it— Third-party and outsourcing dependencies: how to identify and document concentration risk and what regulators expect firms to have done about it— The role of the board and senior management: accountability under SMCR, the governance oversight requirements, and why operational resilience is not an IT or operations issue in isolation— Lessons from FCA supervisory engagement and industry incidents — what has gone wrong for other firms and what your self-assessment should do differently as a result— How operational resilience connects to your broader risk management framework, business continuity planning, and Consumer Duty obligations around service continuityThis episode is essential listening if your firm:— Has not updated its self-assessment since the March 2025 implementation deadline— Has set impact tolerances but not yet tested whether it can remain within them under realistic disruption scenarios— Is approaching an FCA supervisory visit or internal audit of its operational resilience framework— Has significant third-party dependencies that are not fully reflected in its mapping or scenario testingResources mentioned in this episode:Compliance Consultant's Operational Resilience Self-Assessment Workbook is a comprehensive, ready-to-use toolkit built for FCA-regulated firms. It provides a structured self-assessment framework, fully formatted workbook, and step-by-step guidance that enables compliance, risk, and operations teams to complete, document, and evidence their operational resilience obligations 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

An FCA supervisory visit is not a conversation. It is a structured regulatory assessment of your firm's systems, controls, and culture — and firms that treat it as an informal check-up are the ones that end up with the most uncomfortable outcomes.Whether it arrives as a routine engagement, a Dear CEO letter follow-up, or a targeted thematic review, an FCA visit demands that your firm can demonstrate compliance, not just describe it. The regulator will want to see documented evidence, speak with key individuals, test your understanding of your obligations, and assess whether the tone from the top matches what is happening on the ground. The gap between what firms believe they have in place and what they can actually evidence under scrutiny is where regulatory risk lives.In this episode, we walk through what genuine FCA supervisory visit preparation looks like — from the moment you receive notification through to post-visit remediation — and why firms that leave preparation to the final weeks are already behind.Whether you are a compliance officer, an MLRO, a senior manager with regulatory accountability under SMCR, or a board member responsible for oversight, this episode gives you the practical framework to approach a supervisory visit with confidence rather than anxiety.We cover:— Understanding the visit: the different types of FCA supervisory engagement, what each signals about the regulator's concerns, and how to interpret the notification you receive— The preparation timeline: what needs to happen immediately, what needs to happen in the weeks prior, and the common preparation mistakes that create unnecessary regulatory risk— Document readiness: the policies, procedures, registers, MI, and board papers the FCA will typically request — and how to ensure they are current, consistent, and evidence actual practice— Individual preparation: how to brief your MLRO, senior managers, and board members, what the FCA expects from key function holders, and how SMCR accountability maps onto visit interviews— Common examination areas: AML and financial crime controls, Consumer Duty implementation, complaints handling, operational resilience, and governance arrangements— The culture question: how the FCA assesses whether compliance is genuinely embedded or performative — and what signals examiners look for beyond the documentation— Managing the visit itself: how to handle information requests, respond to examiner questions accurately, and avoid the well-intentioned answers that create additional lines of inquiry— Post-visit: how to interpret feedback, respond to findings constructively, and turn remediation into a genuine compliance improvement rather than a repeat exerciseThis episode is essential listening if your firm:— Has received FCA notification of an upcoming supervisory visit or thematic review— Has not conducted a structured internal readiness assessment against current FCA priorities— Has senior managers who have never been interviewed by a regulator and do not know what to expect— Has previously received FCA feedback and wants to ensure remediation is fully evidencedResources mentioned in this episode:Compliance Consultant's FCA Supervisory Visit Preparation Playbook is a comprehensive, ready-to-use toolkit for FCA-regulated firms. It provides a structured preparation framework, document readiness checklists, individual briefing guides, and post-visit remediation templates — everything your firm needs to approach regulatory scrutiny in an organised, evidenced, and confident 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.

Every regulated firm has a compliance risk register. Far fewer have one that genuinely reflects their risk profile, drives management decision-making, or would survive scrutiny from the FCA, an internal auditor, or a skilled person examiner.A compliance risk register is not a spreadsheet exercise. It is the foundation of your firm's entire risk management framework — the document that should tell your board, your senior managers, and your regulator exactly what risks your firm faces, how severe they are, what controls are in place to manage them, and whether those controls are actually working. When it is built properly, with meaningful heat mapping that reflects real likelihood and impact assessments, it becomes one of the most powerful governance tools a compliance function can own. When it is built poorly, it becomes a liability.In this episode, we examine what a genuinely effective Compliance Risk Register looks like, how heat mapping should work in practice, and why the firms that treat risk registers as an annual formatting exercise are the ones most likely to be caught out when something goes wrong.Whether you are a compliance officer, an MLRO, a risk manager, or a senior manager with governance accountability under SMCR, this episode gives you the practical framework to assess whether your risk register is fit for regulatory scrutiny.We cover:— The regulatory expectation: what the FCA expects a compliance risk register to demonstrate and how it features in supervisory visits, s166 reviews, and governance assessments— Risk identification: how to ensure your register captures the full spectrum of regulatory, operational, conduct, and financial crime risks relevant to your firm's actual business model— Likelihood and impact scoring: how to apply consistent, defensible criteria that produce meaningful risk ratings rather than subjective or politically influenced assessments— Heat mapping in practice: how to build and interpret a compliance heat map that gives your board and senior management genuine visibility of your risk landscape— Inherent versus residual risk: why the distinction matters, how to assess control effectiveness honestly, and what regulators think when residual scores look suspiciously low— Linking risks to controls: how your register should connect to your compliance monitoring programme, your audit findings, and your management information framework— Consumer Duty and conduct risk: how to incorporate customer outcome risks into your register in a way that reflects the FCA's current supervisory priorities— Dynamic risk management: how frequently your register should be reviewed, what should trigger an out-of-cycle update, and how to evidence that it is a living document rather than an annual exercise— SMCR accountability: how risk register ownership maps to Senior Manager responsibilities and why named accountability matters when control failures are traced back through the governance frameworkThis episode is essential listening if your firm:— Has a risk register that has not been substantively updated since Consumer Duty implementation— Produces heat maps that show predominantly green or amber ratings regardless of actual control effectiveness— Is preparing for an FCA supervisory visit, s166 review, or internal audit of its risk framework— Has senior managers who cannot articulate the firm's top compliance risks without referring to a documentResources mentioned in this episode:Compliance Consultant's Compliance Risk Register with heat mapping is a comprehensive, ready-to-use toolkit for FCA-regulated firms. It provides a structured risk identification framework, consistent scoring methodology, fully formatted heat mapping tools, and governance templates that enable compliance teams to build and maintain a risk register that reflects genuine regulatory best practice.Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Payment service providers operate in one of the most rapidly evolving regulatory environments in UK financial services. Yet the compliance risk registers many PSR-authorised firms rely on were built for a different business model, a different regulatory framework, or — in some cases — barely built at all.A compliance risk register is not optional for payment institutions, e-money institutions, or registered account information service providers. It is the foundation of your firm's risk management framework — the document that should tell your board, your senior managers, and your regulator exactly what risks your firm faces, how they are controlled, and whether those controls are working. Without heat mapping that genuinely reflects your risk profile, your firm is managing risk it cannot see.In this episode, we examine what a genuinely effective PSR-specific Compliance Risk Register looks like, why payment firms face a distinct set of regulatory risks that generic frameworks consistently fail to capture, and how heat mapping should function as a real decision-making tool rather than a colour-coded formality.We cover:— The PSR regulatory landscape: FCA authorisation requirements, Payment Services Regulations 2017 obligations, and what the regulator expects a payment firm's risk framework to demonstrate— Payment-specific risks your register must capture: safeguarding failures, agent oversight, APP scam liability, strong customer authentication, operational continuity, and financial crime exposure— Likelihood and impact scoring: applying consistent, defensible criteria that reflect regulatory reality rather than organisational optimism— Heat mapping in practice: building a compliance heat map that gives your board genuine visibility of your PSR risk landscape— Inherent versus residual risk: how to assess control effectiveness honestly and what examiners think when residual scores look implausibly low— Safeguarding as a risk category: reflecting safeguarding obligations accurately within your register given the FCA's intensifying supervisory focus on payment firm failures— Dynamic risk management: review frequency, out-of-cycle update triggers, and evidencing that your register is a living governance document rather than an annual exercise— AML and financial crime risk: embedding MLRs 2017 obligations within your PSR risk framework and ensuring your register reflects your firm's specific exposureThis episode is essential listening if your firm:— Is a payment institution, e-money institution, or AISP that has not reviewed its risk register against current FCA and PSR supervisory priorities— Has a risk register adapted from a generic template that does not reflect payment-specific regulatory obligations— Is preparing for an FCA supervisory visit or s166 review, or is subject to the FCA's heightened scrutiny of the payments sector— Has experienced safeguarding, fraud, or operational failures not adequately reflected in its current risk profileResources mentioned in this episode:Compliance Consultant's PSR Compliance Risk Register with heat mapping is a ready-to-use toolkit built specifically for payment institutions and e-money institutions. It provides a PSR-specific risk identification framework, consistent scoring methodology, fully formatted heat mapping tools, and governance templates enabling compliance teams to build and maintain a risk register that reflects genuine regulatory best practice for the payments sector.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.

Filing a Suspicious Activity Report is one of the most consequential decisions a compliance professional makes. Get it wrong in either direction — failing to file when you should, or filing without adequate reasoning — and the personal consequences under SMCR can be severe.The SAR regime sits at the heart of the UK's anti-money laundering framework. The Proceeds of Crime Act 2002 and the Terrorism Act 2000 create clear obligations for regulated firms, and the NCA's Financial Intelligence Unit processes hundreds of thousands of reports each year. Yet the quality of SAR decision-making across the sector remains deeply inconsistent. MLROs are making filing decisions without documented reasoning. Defence Against Money Laundering protections are being claimed without adequate evidential foundations. And when things go wrong, the paper trail — or absence of one — tells the whole story.In this episode, we examine what genuinely robust SAR decision-making looks like, how to document your reasoning in a way that is defensible under scrutiny, and why the MLRO's personal liability makes this one area of compliance where cutting corners is never a calculated risk worth taking.Whether you are an MLRO, a deputy MLRO, a nominated officer, or a senior manager with AML accountability, this episode gives you the practical framework to assess whether your current SAR process would withstand regulatory or law enforcement scrutiny.We cover:— The legal framework: POCA 2002, the Terrorism Act 2000, and the specific obligations that attach to MLROs and nominated officers when suspicion arises— What constitutes suspicion: the legal threshold, how courts have interpreted it, and the common misunderstandings that lead to both under-reporting and over-reporting— The DAML process: how to seek a Defence Against Money Laundering correctly, what the NCA expects, and how to document the decision and outcome adequately— Internal SAR handling: how suspicion should be escalated internally, what the MLRO must consider before making a filing decision, and how that consideration must be recorded— Documenting the decision not to file: why a decision to take no further action carries exactly the same documentation obligations as a decision to report — and why absent records are indefensible— Tipping off and prejudicing an investigation: where the boundaries lie, how to manage ongoing customer relationships during the consent period, and the operational risks that arise— Quality over quantity: what the NCA and FCA expect from SAR content, why poor-quality reports undermine the regime, and how to write a report that provides genuine financial intelligence value— SMCR and personal liability: how SAR failures are traced to named individuals and why the MLRO cannot rely on process documentation alone to demonstrate adequate discharge of responsibilitiesThis episode is essential listening if your firm:— Has an SAR process that lacks a documented decision-making framework accessible to all nominated officers— Has MLROs or deputies who have never received structured training on SAR quality and documentation standards— Is preparing for an FCA supervisory visit, s166 review, or internal AML audit— Has previously received NCA or FCA feedback on SAR quality or decision-making adequacyResources mentioned in this episode:Compliance Consultant's SAR Decision-Making & Documentation Toolkit is a comprehensive, ready-to-use resource for FCA-regulated firms. It provides a structured decision-making framework, documentation templates, internal escalation guides, and worked examples that enable MLROs and nominated officers to make, record, and evidence SAR decisions to a standard that reflects current NCA, FCA, and FATF 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.

A Compliance Monitoring Programme is one of the most powerful tools a regulated firm has. It is also one of the most consistently underused — and the FCA's supervisory findings show that the regulator is increasingly focused on whether monitoring is genuinely risk-based or simply cyclical and superficial.The obligation to monitor compliance is not discretionary. Whether your firm is FCA-authorised under FSMA or regulated under the Payment Services Regulations, you are expected to have a structured, documented, and risk-proportionate programme that tests whether your controls are working, identifies weaknesses before they become regulatory failures, and feeds meaningful intelligence to senior management and the board.In this episode, we examine what a genuinely effective Compliance Monitoring Programme looks like, how to build one that reflects your firm's actual risk profile, and why firms that treat monitoring as a scheduling exercise are storing up significant regulatory exposure.Whether you are a compliance officer, an MLRO, or a senior manager with oversight accountability under SMCR, this episode gives you the practical framework to assess whether your current programme is fit for regulatory scrutiny.We cover:— The regulatory basis for compliance monitoring and what the FCA expects during a supervisory visit or s166 skilled person review— The difference between a risk-based monitoring programme and a compliance calendar — and why that distinction matters enormously when something goes wrong— How to scope your programme correctly: mapping regulatory obligations, identifying high-risk activities, and ensuring your monitoring universe reflects where customer harm could actually occur— Designing individual monitoring reviews: methodology, documentation standards, and what constitutes adequate evidence of completion— Reporting and escalation: how findings should reach senior management and the board, and how to evidence that outputs have generated meaningful action— The Consumer Duty dimension: testing customer outcome delivery across the four outcome areas and feeding results into your annual board report— AML monitoring obligations under the MLRs 2017 and how transaction monitoring, file reviews, and control testing sit within your broader programme— How personal accountability under SMCR applies when monitoring failures allow regulatory breaches to go undetected— Practical guidance on documentation, annual review cycles, and embedding monitoring outputs into your governance frameworkThis episode is essential listening if your firm:— Has a monitoring programme that has not been updated to reflect Consumer Duty obligations— Produces monitoring reports that are filed rather than acted upon— Is preparing for an FCA supervisory visit, s166 review, or internal audit— Has experienced a regulatory failing that effective monitoring should have caught earlierResources mentioned in this episode:Compliance Consultant's Compliance Monitoring Programme Builder is a ready-to-use toolkit for FCA-regulated firms and PSR-authorised payment service providers. It provides a structured programme framework, risk-based scoping methodology, and fully formatted review templates to help compliance teams build and operate a monitoring programme that reflects current FCA expectations and genuine best practice.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.

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 confidenceThis 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 realityResources 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 currentThis 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 requirementsResources 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 avoidThis 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 assessmentResources 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 titleThis 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 implementationResources 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 identifiedThis 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 reportResources 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 requiresThis 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 implementationResources 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 proprietyWe 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-ukCompliance 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 regulatorWhether 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 writesWe 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-ukCompliance 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 atWe 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-ukCompliance Consultant — Making Compliance Work.

Receiving a query from the FCA is one of the most stressful moments in a compliance professional's calendar. Whether it's a supervisory information request, a data query, a Dear CEO letter follow-up, or the opening move in a more formal supervisory engagement, how you respond matters enormously — and most firms simply aren't prepared.In this episode, we're talking about the FCA Query Response Pack — what it is, why every FCA-regulated firm should have one in place before they ever need it, and how a structured, well-prepared response framework can protect your firm, your senior managers, and your regulatory relationship.What we cover in this episode:We begin by looking at the different types of FCA contact that typically require a formal response — from routine supervisory data requests and thematic review questionnaires through to more serious Section 165 information requests and supervisory notices. Understanding the nature of the query you've received is the critical first step, and many firms underestimate how different the appropriate response strategy can be depending on the type of contact involved.We then walk through the core components of an FCA Query Response Pack — the internal triage process, the escalation framework, the roles and responsibilities of senior managers under SMCR, how to coordinate your response across legal, compliance, and operational functions, and the documentation standards you need to maintain throughout the process.We discuss the importance of response tone and framing — because the FCA reads between the lines. An overly defensive response can signal problems that weren't originally on their radar. An incomplete or poorly organised response can invite further enquiry. And a delayed response, without a properly managed extension request, can escalate a routine query into something far more serious.We also cover the common mistakes firms make when responding to FCA queries — including responding too quickly without proper internal review, failing to identify the appropriate Senior Manager with accountability for the subject matter, providing inconsistent information across different response channels, and neglecting to retain proper records of what was submitted and when.Why this matters right now:The FCA's supervisory model has become significantly more data-driven and proactive. Firms are receiving more frequent information requests as the regulator seeks to identify harms earlier and intervene faster. The Consumer Duty has added a new layer of supervisory interest in how firms evidence their outcomes, and the FCA has made clear that it expects firms to be able to respond to queries promptly, accurately, and with appropriate senior manager oversight.Firms without a structured response framework are operating at a significant disadvantage. When a query lands on your desk, the last thing you want to be doing is working out your process from scratch while the clock is ticking.The practical takeaway:By the end of this episode, you'll understand the anatomy of a well-managed FCA query response process, the internal governance steps that should sit behind every formal response, and the documentation you need to protect your firm if a query escalates into a deeper supervisory engagement.If you want a ready-built solution, our FCA Query Response Pack is available to download directly from Compliance Consultant at complianceconsultant.org — a comprehensive, practical resource built by qualified regulatory consultants.Who this episode is for:This is essential listening for compliance officers, MLROs, legal counsel, Chief Risk Officers, and any Senior Manager with regulatory oversight responsibility at an FCA-authorised firm. If your firm has ever received — or is likely to receive — a formal communication from the FCA requiring a response, this episode will give you the framework and confidence to handle it properly.Visit us at complianceconsultant.org or call us on 0800 689 0190.