executive profile


Pre-appointment and periodic screening of c-suite executives and key staff in firms regulated by the Financial Conduct Authority (FCA) or HM Revenue & Customs, including staff who deal or arrange deals in investments and investment managers.

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Fit and Proper test for Senior Personnel and Key Employees

Senior Executives holding Approved Person roles and individuals in Certification Functions represent the public face of a regulated firm.  Their profiles contribute to customer and investor perception of a firm's ethics and culture.  The Financial Conduct Authority (FCA) Handbook includes standards to be applied under the Fit and Proper test for Employees and Senior Personnel.

Certain persons associated with businesses supervised by HM Revenue & Customs (HMRC) for anti-money laundering purposes, are subject to the Fit and Proper test under the Money Laundering Regulations.  The objective is to ensure suitability of people in key roles (eg. applicants, beneficial owners, officers and senior management of the business). Responsible persons must pass the relevant test before the business can register, and remain registered, with HMRC.


Ensuring leadership by the right people is a key element of regulatory compliance and stakeholder management. Pre-employment checks and periodic revalidation of the accuracy of employee risk profiles, helps reduce the risk of employing the wrong people.

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STAFF VETTING

Completing appropriate due diligence contributes to employee (or candidate) assessment and ensuring the retention (or hiring) of effective and honourable personnel.

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EXAMPLE GUIDANCE - REFERENCE SOURCES

Staff Vetting

Pre-employment checks help to reduce the risk of employing the wrong person. A Chartered Institute of Personnel and Development factsheet looks at risk in the recruitment process. The CIPD refer to conducting due diligence to discover whether an applicant might bring the organisation into disrepute, or cause difficulties with colleagues, managers, customers or suppliers.

CIPD Factsheet
Fit & Proper Test

SMCR firm assessment of staff competence and capability should consider convictions, dismissals and suspensions from employment for drug or alcohol abuses or other abusive acts in relation to a person's continuing ability to perform the particular FCA Designated Senior Management function or an FCA Certification Function for which the person is, or is to be, employed.

FCA FIT 2.2.2A
Associated Persons

Ministry of Justice Guidance for anti-bribery identifies that procedures may be standalone or part of wider guidance, for example on recruitment or on managing a tender process in public procurement. Procedures should be practical and realistic to achieve the firm's stated anti-bribery policy objectives across all of the organisation’s functions.

MOJ Guidance
Criminal Record

Employers might complete criminal record searches on job applicants via the Disclosure and Barring Service ('DBS'). Detailed checks can be sought for some roles in healthcare or childcare. Basic checks are used for financial services professionals (regulated by the Financial Conduct Authority), to check for unspent convictions or conditional cautions.

Which Check?

HOW WE HELP CLIENTS

Regulatory Compliance

Enhanced Due Diligence to asses risk

Resource Screening

Pre-employment & key-person risk assessment

Associated Persons

Bribery and tax evasion risk-assessment

Counterparties

Pre-contract credential-check/validation

CONFIDENTIALITY ASSURED

As part of executive-profiling we are accustomed to researching the people behind corporate and commercial transactions, and their associates, to assess for the presence of any significant anomaly, red-flag, or unexplained lack of transparency; and which might indicate an increased risk to our clients.

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