S166 Skilled Person
Under the FSMA 2000, the FCA’s Section 166 review is an independent review by a third party (a ‘skilled person’) about aspects of a regulated firm’s activities where the FCA has concerns or requires further analysis.
The review can be intensive and intrusive, involving a wide-ranging review of the firm’s financial crime controls, covering firm-wide governance arrangements through to detailed analysis of customer files and alert decisioning.
Its consequences can be wide and challenging for a firm, not to mention extremely costly, so it’s important that the right skilled person is selected at the outset.
We understand that all firms’ business activity, customer base and risk appetite will differ. We therefore work closely with our clients to develop a deep understanding of their business and FCC framework in order to apply an effective, proportionate and risk based approach to our S166 or independent reviews.
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Plenitude's Role
Plenitude are appointed to the Skilled Person Panel for Lot E: Financial Crime. As defined by the FCA, this highlights our proven expertise on:
Advice, skills and technical expertise in financial crime, anti-money laundering, anti bribery and corruption, sanctions, cryptocurrency and payments solutions, tax evasion, market abuse (including insider dealing and market manipulation), and governance of these areas.
Whether you need Plenitude to act as your Skilled Person or support you through the Skilled Person / S166 review, we’re here to help.
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Independent Assessment or Audit
Independent assessment or audit of your existing FCC framework to proactively identify potential control gaps or weaknesses.
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Remediation / Response Plan
Development of your remediation or response plan to effectively address regulatory feedback or feedback from an S166 Review.
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S166 Support Firm Side
Provide advice and support to successfully navigate an S166 review, including documentation reviews, training and awareness activities ahead of walkthroughs and staff interviews.
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Transformation and Remediation Support
Work with you to implement the required enhancements as part of a remediation project or programme of work.
Benefits and Outcomes Delivered
We understand that all firms’ business activity, customer base and risk appetite will differ. We therefore work closely with our clients to develop a deep understanding of their business and FCC framework in order to develop an effective, proportionate and risk-based approach to financial crime risk management.
Plenitude’s services and capabilities are grounded in our multi-jurisdictional expertise, our proprietary suite of tools and RegTech products, and our deep understanding of sector-specific regulatory obligations and needs. This enables us to deliver the following benefits and outcomes to our clients:
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Market-leading advisory, transformation and technical expertise with tech-enabled delivery
Our full-service offering enables us to meet all of our clients’ needs. Our tech enabled delivery approach leverages our extensive suite of proprietary tools and RegTech products which enables us to accelerate delivery and reduce overall engagement costs.
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Regulatory compliance and assurance
We enable clients to fully understand and meet their regulatory obligations, along with the ability to present robust documentation to demonstrate their conformance with regulatory requirements.
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Enhanced efficiency, effectiveness and cost reduction
Our tech advisory, data analytics services and RegTech products enhance efficiency, optimise detection accuracy, streamline workflows and reduce false positives, leading to improved effectiveness and significant cost savings.
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Access to cutting edge technology and future-proofed compliance
We enable our clients to stay ahead of evolving regulations and criminal tactics by optimising current systems and controls, deploying the latest AI-powered technology and data analytics services.
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Compliance transformation
We partner with clients to transform their entire compliance function, fostering a culture of data-driven decision-making and continuous improvement.
Our specialists
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Alan Paterson
Founder & CEO
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Asad Choudhary
Partner
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Chris Bone
Senior Executive
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Daniel Keay
Senior Executive
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Briony Rippington-Bond
Chief of Staff
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Manuel Fajardo
Head of Digital Assets
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Alex Brennan
Senior Manager
Related articles
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Get in touch to speak to the team or to request a demo
Our best-in-class team are committed to building a secure financial system, safeguarding society, and empowering our clients to meet their regulatory obligations.
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