SARs: Are Your Suspicious Activity Reports Defensible Decisions — or Just Defensive Documentation?
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 ad...
26 Feb 19min
Compliance Monitoring: Is Your Programme Actually Testing What Matters — or Just Ticking Boxes on a Schedule?
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...
26 Feb 25min
Section 166 Skilled Person Review: What It Really Means for Your Firm and How to Face It Prepared
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...
26 Feb 18min
Sanctions Screening: Is Your Firm Actually Managing Sanctions Risk — or Just Running Names Through a System?
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 landsc...
26 Feb 16min
AML Risk Assessment: Is Your Firm's Picture of Its Money Laundering Risk Accurate — or Just Assumed?
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, e...
26 Feb 19min
SMCR Handovers: When a Senior Manager Leaves, Is Your Firm Handing Over Accountability or Just Access?
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 regu...
26 Feb 20min
Vulnerable Customers: Is Your Firm Identifying Who Needs More Support — or Just Assuming It Will Be Obvious?
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...
26 Feb 9min
FCA Conduct Rules Breaches: When Something Goes Wrong, Is Your Investigation Process Actually Fit for Purpose?
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 — i...
26 Feb 22min
