s166 Skilled Person Review

As an appointed firm on the Financial Conduct Authority (FCA) and Prudential Regulation Authority’s (PRA) Skilled Person Panel, Kroll has a strong track record in conducting skilled person reviews across a range of financial services industries and thematic areas.

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The skilled person report is one of the supervisory and enforcement tools that the FCA and the PRA use under Section 166 (s166) of the Financial Services and Markets Act, as amended by the 2012 Act. The regulators can commission an independent skilled person to obtain an assessment of areas of concern within a firm or to collect, analyze and verify information. It is used for four main purposes:

  • To diagnose risks 
  • To monitor identified risks
  • To prevent or reduce risks from occurring and escalating 
  • To remediate risks appropriately where they have occurred

Kroll is an appointed firm on the FCA and PRA’s Skilled Person Panel in eight lots:

  • Lot A: Client Assets
  • Lot B: Governance and Individual Accountability 
  • Lot C: Controls and Risk Management Frameworks
  • Lot D: Conduct of Business
  • Lot E: Financial Crime
  • Lot F, H and I: Prudential

Our experienced team of former regulators, industry practitioners and professional advisers has undertaken more than 60 skilled person reviews in recent years.

Our approach to skilled person reviews is focused on delivering an outcome that addresses the firm’s issues, makes proportionate and workable recommendations and restores the regulator’s confidence. These reviews vary in nature and include assessments of the adequacy and effectiveness of a firm’s control frameworks, testing their application of policies and procedures and confirming that remedial work has been implemented. 

Each skilled person review is unique; however, our guiding principles are always to:

  • Work with the firm and regulator to build a strong understanding of the firm’s business environment and the context for the review from the outset, so that we deliver a tailored, cost-effective and proportionate review 
  • Perform an independent, objective report based on evidence and our strong technical competence, with practical recommendations 
  • Conduct a robust and efficient process to established timeframes and budget that minimizes disruption to the firm’s business
  • Regularly discuss our emerging findings with the firm and regulator throughout the process so there are no surprises in the draft and final reports
  • Perform the review in an open, proactive and independent manner, with timely communication with both the firm’s stakeholders and the regulator

Where we are not appointed as the skilled person, we can provide advice and assistance to firms: 

  • To prepare for a skilled person review
  • During the process to support efforts to achieve an efficient and effective review 
  • With remediation where the skilled person has made recommendations
Connect with us
Connect with us
Nick Bayley
Nick Bayley
Managing Director
Financial Services Compliance and Regulation
Mark Turner
Mark Turner
Managing Director
Financial Services Compliance and Regulation

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