Skilled Person Reviews (S166) Case Studies

Kroll is recognized as a regulatory compliance expert by the UK’s financial services regulators, the FCA and PRA, where we are an appointed firm on their Skilled Person (S166) Panel. Our experienced team of former regulators, industry practitioners and professional advisers has undertaken over 60 Skilled Person reviews in recent years.

Skilled Person Review of a UK Wealth Manager

A Kroll team was engaged to undertake a Skilled Person (S166) Review of a UK wealth manager. The focus of the review was to assess whether the firm had adhered to its clients’ investment objectives and to ensure that all relevant client documentation was in line with FCA expectations. Central to this review was suitability and compliance with the relevant FCA Conduct of Business (COBS) rules.

Our team began by carefully mapping the regulatory rules to the processes within the wealth management firm. This included robust analysis of client details, including classification of the client, their investment objectives, suitability of their investments and the communication they had received from the firm. The review also involved interviewing the firm’s staff to assess their skills, knowledge and expertise to deliver the services sold to clients.

Our team identified numerous weaknesses which were reported to both the regulator and the wealth manager’s parent company, as required by the Skilled Person process. We then supported the successful transfer of the wealth manager’s current clients to the parent company, which eliminated any risk of client detriment. The work was done over a period of several months in careful communication with the individual clients.

Project outcomes

As a result of Kroll’s work:

• The parent company was able to undertake a well-considered and robust compliance remediation program
• The firm avoided further regulatory action 
• The parent company has continued to work with Kroll for many years, most recently on its prudential framework as well as anti-money laundering and suitability compliance