Background checks for SMCR
Whilst it has always been the case that a firm must ensure that an individual applying for a controlled function must be fit and proper under the approved persons regime, there was never an explicit regulatory requirement to carry out background checks on the individual.
However, under the Senior Managers and Certification Regime, there is now an explicit requirement to perform background checks both at the point of an individual becoming an approved person and on an ongoing basis.
Background checks for SMCR
Whilst it has always been the case that a firm must ensure that an individual applying for a controlled function must be fit and proper under the approved persons regime, there was never an explicit regulatory requirement to carry out background checks on the individual.
However, under the Senior Managers and Certification Regime, there is now an explicit requirement to perform background checks both at the point of an individual becoming an approved person and on an ongoing basis.
To clarify the new SMCR has introduced two new requirements:
1. For senior managers, there is a mandatory requirement to perform criminal background checks; and
2. Under the certification regime, there is a requirement to re-certify individuals at least once a year. Whilst this in itself does not create a mandatory requirement to perform background checks, this does increase the profile of the ongoing fitness and proprietary review process and – hence – the option of performing the background checks.
To help our clients navigate these new background check requirements we have partnered with Vero Screening to produce SMCR Checks
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Vero Screening
1. For senior managers, there is a mandatory requirement to perform criminal background checks; and
2. Under the certification regime, there is a requirement to re-certify individuals at least once a year. Whilst this in itself does not create a mandatory requirement to perform background checks, this does increase the profile of the ongoing fitness and proprietary review process and – hence – the option of performing the background checks.
Screening packages
We've put together a set of best practice screening packages.
These will help you meet the criteria identified by the Financial Conduct Authority as relevant to the assessment of whether an individual is 'fit and proper to perform a role', and our packages can be used for existing employees or new employees.
You can register your interest in SMCR Checks by filling out the online form on Vero’s website which you can access using the link below.
