Through issuance of Requirement Notices, we are seeing continued deployment by the UK regulators of the FSMA Section 166 tool (Reports by Skilled Persons) to assess firms’ governance, risk and control frameworks, conduct of business, customer outcomes, financial crime, and financial resilience arrangements in a targeted and outcomes-focused way. Successful delivery of these reviews demands more than technical analysis; they require clear insight, practical judgement and the ability to translate regulatory expectations into meaningful change.
How we work with regulators and firms
We combine deep regulatory expertise with a pragmatic, delivery-focused approach, supporting both regulators and firms throughout the lifecycle of a Skilled Person Review:
End-to-end review delivery
We deliver Skilled Person reviews from initial scoping, performance of fieldwork, through to final reporting. Our approach is underpinned by a robust internal Quality Assurance Framework, ensuring consistency, technical accuracy and robust outcomes. We combine deep regulatory expertise with disciplined project management to deliver to tight regulatory deadlines without compromising quality.
Root cause analysis
We go beyond surface-level findings to identify the true driver of the issues set out in Requirement Notices. Our reviews focus on uncovering underlying control weaknesses, cultural factors and systemic failings, adding value for firms and Senior Management in understanding ‘what’ went wrong and also the ‘why’. This facilitates effective remediation and reduces the risk of repeat issues.
Actionable recommendations
Our recommendations are practical, proportionate and clearly traceable to the facts established via our fieldwork. We align our outputs with FCA expectations, translating findings into clear, prioritised, and time bound actions that can be implemented efficiently. We also consider cost, operational impact and proportionality, ensuring solutions are both effective and sustainable.
Assurance support
We provide independent assurance over remedial activity, helping firms demonstrate progress and regain regulatory confidence. This includes validating the implementation, effectiveness and embeddedness of previous recommendations, particularly in the context of lifting Voluntary Requirements. Our support provides comfort, aligned to the ICAEW assurance standards for Skilled Persons Assurance, to Boards and regulators that regulatory issues have been properly addressed.
Regulator and stakeholder engagement
We work closely with regulators and key stakeholders, including firm Senior Management, throughout the review process, maintaining independence while adopting a constructive and solutions-focused approach. Our team is experienced in managing sensitive regulatory interactions, ensuring clear communication, transparency and alignment at each stage of the review.
As part of our integrated legal services offering, as noted above, we also provide support to firms in relation to pre-Skilled Person reviews, including remediation, preparation ‘shadow’ Section 166 reviews, as well as provision of assurance upon completion of Skilled Person reviews.
