Bank Financial Crime s166 Skilled Person Review

  • Posted on: 1 June 2018

Our client is a 40 year established UK Bank with a parent based in the Middle East, with close links to some high risk jurisdictions.  They had previously been fined for FCR failings and their Board was therefore extremely nervous when an FCA visit led to a s166 review of their current FCR failings.

Compliancy Services was instructed to assist the Bank mitigate the worst case scenario and avoid further enforcement action from the FCA. This was achieved through a programme of ‘enhanced remediation’, board coaching, and proactive engagement with both the Skilled Person and regulator. Our client has avoided a further fine and exceeded their expectations in terms of management of the s166 process and its outcomes. The Bank is also far better prepared for the future by having in place a robust FCR Management Framework to protect it in future.

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