August 2017 Offer

We all know that the summer months can be quiet for IFAs and what better time to get those awkward jobs dealt with?

At Compliance Consultant we also know that whether you are independent or restricted, there are a number of issues that need addressing.

“We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure …….. further work is required by the sector”

The FCA stated in their report on “Suitability” in May  that “We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure and further work is required by the sector to improve the initial disclosure (includes firm’s costs and services).”

Having met with the FCA Supervision Team (authors of the report) recently we have a good handle on what they mean and what they hoped to see already in place.

Additionally there was also a great deal of discussion around the suitability letter construction and what content should be included.

Regarding the Senior Managers & Certification Regime, ( we have already worked on this for banking groups and know what is involved, the final tweaks are awaited but

In the details released on 26th July 2017, the FCA said the requirements will include “responsibilities maps, handover procedures, and will need to make sure that there is a senior manager responsible for every area of their firm”.

This means that your procedures need to be identified, mapped and recorded with owners and relevant controls.

What We Are Offering

To Help You Ensure You Are Comfortable With Your Compliance Affairs, We Have Two Offers;

5 Days Work for the price of 4

If you have a piece of work that needs doing, we will arrange to provide 5 days service either at your work site or from a distance (typically report writing etc) at a 20% Discount if at least 5 days work is booked.

What Does This Mean?

This means simply whereby we would normally charge in the range of £650 to £850 for a days’ consultancy work, over a week that would be £3,250 to £4,250 – with our offer that is reduced to £2,600 to £3,400 and no VAT!

As An Extra

We Operate A “Benchmarking Audit” and that is on special offer until 4th August from £2,600 discounted to £2,080 with no VAT!

We can offer these discount ONLY FOR WORK BOOKED IN BY

5.00pm 4th AUGUST 2017

CLICK HERE to register your interest and get a copy of our

“Suitability Guide” absolutely Free!

Don’t want the guide? Need to talk to us straight away? Call 0203 815 7939 now!


Incubator/Nursery UK Financial Services Companies – Authorisations


Sometimes, Authorisation Is NOT The Answer

We are often approached by start-ups and individuals who want to get FCA authorisation but who have little or no experience. Much as we could take them down the path of authorisation (only to be rejected later on), we don’t. We recommend they either get a couple of years experience working in the chosen sector or, if they are confident enough, to try an incubator or nursery company, acting as an Appointed Representative for the parent entity.

We list some companies that may be worth trying below, but have no connection with them or receive any benefit from them at all.

Norfolk House
31 St James’s Square
United Kingdom
Sturgeon Ventures –
Administration and Sturgeon Academy
Linstead House
9 Disraeli Road
SW15 2DR
Kession Capital Limited
(City Office)
1 Fore Street
(North West Office)
7th Floor
Hyde House
Edgware Road
+44 (0)207 558 8800 (Switchboard) (skype)
UK & Europe:
Matti Pekkola
Contact Via Website
Daniel Maycock

We wish you the very best of luck with your future!

A solution to meet MiFID II face to face note taking requirements

voice notes transcription

voice notes transcription

A solution to meet MiFID II face to face note taking requirements

For 10 years VoiceNotes has been providing a secure, high-quality transcription service to the finance industry, allowing you to dictate your meeting notes from any phone, 24 hours a day, seven days a week.

This results in contemporaneous minuted notes addressing the record-keeping requirement. Website: Contact: Ben Wilder –

UK Regulatory Financial Services Compliance Specialist Services Provider ref PRA & FCA

compliance meaning-compliance officer-compliance definition-compliance

A compliance definition is difficult to obtain other than “We define compliance within our firm as the function of identifying relevant legislative, regulatory and best practice requirements and then implementing the required changes to our systems and controls to facilitate adherence to these obligations on an ongoing basis.”

However, every firm needs external perspective and Compliance Consultant – as a leading regulatory compliance specialist consultancy have many different and adaptable services to offer.

Contact us on 0203 815 7939

S166 Reviews Cost Firms £110 Million

skilled person report s166 section 166

Revealing the figure in its annual report and accounts, the FCA said that aggregate costs for firms, including reviews in progress since April 2013, was £110 million, net of VAT, with one review constituting most of it.

Over the 12 months, there were 49 cases for which the regulator used its s166 powers most of which were concerning conduct of business, up from 42 year-on-year.

Elsewhere in the accounts, the FCA revealed that it made a loss of £8.6 million, compared to a £3.8 million gain over the same period in 2016.

When combined with the losses incurred by the Payment Systems Regulator, the group loss is £9.2 million. The group had ended the previous year with a surplus of £21.3 million.

While the City watchdog’s fee income increased from £517.1 million to £543.9 million, other income went down to £20.9 million from £34.8 million, a decrease of 40%. This was mainly attributed to a decline in income from skilled persons reviews of £13.3 million.

Total staff costs were £329 million, marginally down from £330.7 million in 2015/16.

The FCA also highlighted that the costs of 15 ongoing reviews of interest rate hedging products from the 2013/14 financial year now stand at £391.5 million, as at 31 March.

 If you need help with a S166 – first get the information from  Responding to a S166  and then call in Compliance Consultant to help you build your case and reduce the overall costs by being prepared.


Questions To Ask [Important] – Regulatory Radar July 2017



MiFID II Regulatory Pieces Are Falling Into Place With The FCA

The final two pieces of UK legislation implementing MiFID II were laid before Parliament on 26th June which give the FCA powers to make certain of the changes to the handbook rules (such as the financial promotion rules) and to carry out certain administrative tasks linked to implementation (such as setting position limits).

 These are the:

Data Reporting Services Provider Regulations

Markets in Financial Instruments Regulations

With that in mind, I thought I would just remind you of what’s happened and what’s on the radar that you may need some assistance with the planning and implementation of.

See Our Special Offers At The Foot Of This Article

Save Money On Your AML Manual & Governance Review!

These areas are;

  1. 4th ML Directive was effected on Monday 26thJune and becomes the Money Laundering Regulations 2017 and affects all businesses, taking over from the 2007 version. This should have already been addressed with the appropriate changes to your AML policy and procedures, but seems to still be causing some firms slight issues, especially around their governance & risk identification and mitigation (risk register).
  2. MiFID II (that which we all love) is effective 3rd January and there are some fairly seismic shifts for many asset and fund managers. For advisers, there are several fairly minor but changes that need to be reviewed. There are also some subtly changes that some firms have overlooked such as “best execution” rules and the reporting. Fees and Costs are another area for consideration. As I am sure you are aware, changes to the right governance (CofI, Inducements etc) all need to be in place for the 3rdJan.
  3. I am sure your preparations for Senior Managers & Certification Regime (SMR or SM&CR) due to be rolled out over 2018 across all firms is well underway, despite not yet having the final rules, the foundations are still going to be the same as for banks. This is going to take huge preparation on the part of all sizes of firms, such as mapping their rules, responsibilities, allocation of roles, appropriate distinctions between functional allocation, appropriate training to directors, NEDs and staff, changes to employment contracts (more in 4 below), breach reporting policy and procedures, Board oversight of conduct related issues, revised KPIs etc, changes to governance and many other aspects that I could bore you with.
  4. Further to 3 above, the SM&CR HR element has to be planned well in advance for SM&CR changes due to employment law legislation. You will need, if you haven’t already, to review the Regulations that Impact People, such as and for example; Threshold Conditions (COND), Principles for Business (PRIN). Senior Management Arrangements, Systems and Controls (SYSC), Fit and Proper Test for Approved Persons (FIT), Principles and Code of Practice for Approved Persons (APER) and Training and Competence (TC).
  5. General Data Protection Regulation (GDPR) This is a European implementation 28th May 2018 ad will take some preparation – especially on the lead gathering, newsletter management, handling, storing and processing of data, appropriate age restrictions etc, disclosure and other aspects of data management.


Questions to ask


  1. Have we reviewed the definitions and procedures in accordance with the MLD4?
  2. Have we updated the CDD/EDD/SDD and Beneficial owner sections?
  3. Have we trained our staff on the changes?
  4. Is our policy up to date?
  5. Is our policy approved by the board?
  6. Would our AML/KYC/FC preparations or current arrangements stand up to independent external scrutiny?
  7. Do you need to review the ‘state of play’ within your firm?



  1. Transaction reporting – Legal Entity Identifiers – Do we understand the requirements?
  2. Information to clients – costs & charges – Are we clear on what changes are required and do we have a clear plan for making those changes appropriately?
  3. Reporting – Are we cear on the new reporting requirements?
  4. Are we happy that our existing systems can provide the new service?
  5. Advice – Are we happy with the new definition?
  6. Suitability – Are we comfortable that oour existing Suitability practices are adequate?
  7. Appropriateness – Are we comfortable that the products we sell are considered “non-complex” or do we need to make changes?
  8. Fair, clear and not misleading – if we provide future performance, do we comply with the new rules?
  9. Communication recording – Are we happy that we have a comprehensive method of recording the content and timings of communications and clearly identify the outcomes accurately?
  10. Inducements – Do we comply with the new rules? Are those we deal with complying with the new rules?
  11. Best execution – Have we made the appropriate changes in our documentation?
  12. Product governance: distribution – Have we enough information to ensure that the products and services we provide are not mis-sold?
  13. Client Agreements – Have we ensured we have a plan to amend agreements and terms & conditions documents appropriately?
  14. Have we trained our staff on the impending changes?
  15. Is our suite of policies up to date?
  16. Are our policies approved by the board?
  17. Would our MiFID II preparations or current arrangements stand up to independent external scrutiny?
  18. Do you need to review the ‘state of play’ within your firm?



  1. Have we planned, in good time, for all SMFs & CRs to receive training on the duty of responsibility, reasonable steps and the regulators’ guidance relative to them?
  2. What steps do we need to take to ensure our has the ability to provide and obtain regulatory references for SMF and Certified roles?
  3. Have we mapped our business against the regulator’s handbook so that we are aware of the impacting changes and where/who will be effected?
  4. Are our record keeping facilities set-up to retain relevant documentation for at least six years after an individual leaves the business?
  5. Have we identified potential conduct risks and implemented controls or mitigation measures?
  6. Is our risk register up to date?
  7. How do the board get made aware of conduct issues? (They are responsible for ALL conduct)
  8. Have we prepared a formal and robust documentation of the firm’s governance arrangements into responsibilities maps and statements of responsibilities, setting out board and committee structures, roles, responsibilities & escalation lines?
  9. Have we mapped existing SIF approvals onto the new SMF framework, and identifying staff potentially subject to the Certification Regime.
  10. Have we trained our staff on the impending changes?
  11. Would your SMR preparations or current arrangements stand up to independent external scrutiny?
  12. Do you need to review the ‘state of play’ within your firm?
  13. Is our Conduct Policy up to date?
  14. Is our policy approved by the board?



Do we as a company understand;


  1. WHY the personal data processed?
  2. Precisely WHOSE personal data is processed?
  3. For each data management process, WHAT and WHEN is personal data processed?
  4. And finally, precisely WHERE is personal data processed?
  5. Is Senior management aware of and regularly discuss data protection?
  6. Are our Data Protection policies and procedures (including retention and disposal schedules);
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Are our Information Security policies and procedures:
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Do we have formal mechanisms in place to identify breaches and handle incidents;
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Do we have clear and accessible fair processing information given to individuals?
  2. Are all our new new projects and initiatives;
  • “privacy-proofed” at the planning stage?
  • reviewed during development, testing and delivery stage, i.e. pre- and post-implementation?
  • ‘Privacy impact assessments’ are conducted when necessary?
  1. Have we trained our staff on the impending changes?
  2. Would your GDPR preparations or current arrangements stand up to independent external scrutiny?
  3. Do you need to review the ‘state of play’ within your firm?

These issues will not be changing any more, if these are not addressed immediately by firms spending a little money now, they are going to be spending absolute fortunes at the last minute. All firms will have to demonstrate “on demand” that they have everything in place.

You may find these links useful and

Any firms that may need assistance with any of these areas can contact us for support on 0203 815 7939. Please be aware that our resources are limited and bookings for this work are already being placed. Depending on the size of your project, discounts of up to 20% are available.

If you would like any further information, please drop me a line.

Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, with 1/3rd Off please click on this link ( and use the code “CCMLD4” in the payment box for a full 1/3rd discount! Hurry because this only valid for the first 25!

If you want to take advantage of our policy checking offer, go to our special offer at but hurry, this is only on sale until the 21st July!

Birth of the Office for Professional Body Anti-Money Laundering Supervision (OPBAS)





On the 15th March 2017, the UK Government announced the creation of a new watchdog for anti-money laundering.

Named the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), it aims to tackle the methods of financial criminals by both stepping up standards of anti-money laundering (AML) supervision and closing loopholes in guidance that can be exploited to move illicit funds.

The UK Government’s ‘Action Plan for Anti-Money Laundering and Counter-Terrorist Financing’, released in April 2016, included an objective to review and improve the effectiveness of AML and CTF supervision. Subsequently, between April and June 2016, HM Treasury undertook a review of the UK AML / CTF supervisory regime. The review involved an audit of the FCA, Serious Fraud Office (SFO), HM Revenue and Customs (HMRC) and the National Crime Agency (NCA).

A key theme running through the review was a lack of consistency and potential confusion caused by the number of supervisory bodies overseeing firms’ activity in this area. It also referred to the guidance provided by legal and accounting firms, which is sometimes conflicting in its message.

All of this has the potential to create loopholes that criminals can exploit – as such there is a need to seek a more consistent approach to both supervision and guidance. OPBAS will seek to better unify the various industry, regulatory and legislative approaches.


OPBAS will have overall responsibility for the various supervisory organisations involved to ensure consistency of approach.#compliance-#fca-regulatory-uk-financial service-consultancy-consultantcy

It will also set out how these bodies can comply with supervisory standards once they are updated to incorporate requirements of the EU’s 4th Anti-Money Laundering Directive (4AMLD), due to be implemented by the UK on the 26th July 2017.

More specifically, OPBAS’s objectives are to:

  • Raise standards and ensure a consistent approach to AML supervision
  • Provide guidance to professional AML supervisory bodies on how to comply with their obligations in line with the updated money laundering regulations
  • Hold enforcement powers to penalise breaches of regulation made by professional AML supervisory bodies
  • Facilitate collaboration between supervisors and law enforcement in terms of tackling money laundering and terrorist financing


OPBAS is due to be legislated for by the end of this year and operational from the start of 2018, and we can anticipate new guidance to be released shortly after this.


OPBAS will become operational several months after the updated money laundering regulations are implemented, but firms will not want to wait until this time to make sure they are compliant.

money-laundering-2017-hmrc-fca-regulation-impact-how t0The new office will sit within the FCA and operate in line with its existing governance structure. AML supervision is already an area of strong focus for regulators and was earmarked as a priority by the FCA in its 2016 / 17 Business Plan as it looked to broaden its Systematic Anti-Money Laundering Programme (SAMLP). This focus will increase into 2017 / 18.

Not only is the focus increasing in terms of regulatory output; the level of insight FCA receives back on these issues continues to increase with the implementation of REP-CRIM financial crime reporting in January 2017. This extra insight being gained by regulators will serve to enhance their view – this may manifest itself in further changes to supervision, and firms will need to continue to keep abreast of any developments.

The creation of OPBAS will mean increased scrutiny of professional AML supervisory bodies in terms of how they supervise AML and CTF compliance. This will create a knock-on effect for firms themselves, which could quickly feel the effects of this closer supervision. Following some uncertainty in terms of AML guidance from a supervisory point of view, the intention of regulators will be to ensure enforcement action is taken should deficiencies be identified – this has been a well-documented challenge in the current regulatory environment.

With the Government response on how money laundering regulations will be incorporated due in April, supervisory bodies may arguably be left with little time to interpret the regulations and revise their rules and guidance for firms in time for the 26th July and 4AMLD. This could in turn challenge firms’ ability to prepare for the changes. Staying abreast of developments in this space with the aim of prompt but proportionate action (when appropriate) should be firms’ current focus.

To help with your Anti-Money Laundering procedures as well as other Compliance support services, please contact us on 0203 815 7939


Looking For a Compliance Consultancy London?


Looking For a Compliance Consultancy London?

The majority of compliance consultancy services are found in London due to the high concentration of financial services firms being located there. Compliance Consultant is no exception, and we have our London office located just outside the City of London, within easy walking distance of most of our major clients. Additionally we have an office on the South Coast, which handles most of the provincial business, from Falmouth to Edinburgh and Belfast to Dover, criss-crossing the UK, to provide a value based service to all clients.

The range of services we offer can vary with the type of client from small Electronic Money Institutions to new banking licences, from Independent Financial Advisers (IFAs) through to Insurance Companies and Payment Institutions, we have a range of products to suit.

Please check out the shops Tab for the latest productised services and discounts.

If you need a Compliance Consultancy London, or indeed, Compliance Consultants uk (as we operate countrywide and even in Europe and the gulf region), then call us on 0203 815 7939 or email