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.Learn More
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.
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
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
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
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?
Enhanced Due Diligence to asses risk
Pre-employment & key-person risk assessment
Bribery and tax evasion risk-assessment