The Compliance Doctor

An FCA supervisory visit is not a conversation. It is a structured regulatory assessment of your firm's systems, controls, and culture — and firms that treat it as an informal check-up are the ones that end up with the...

Every regulated firm has a compliance risk register. Far fewer have one that genuinely reflects their risk profile, drives management decision-making, or would survive scrutiny from the FCA, an internal auditor, or a...

Payment service providers operate in one of the most rapidly evolving regulatory environments in UK financial services. Yet the compliance risk registers many PSR-authorised firms rely on were built for a different...

Filing a Suspicious Activity Report is one of the most consequential decisions a compliance professional makes. Get it wrong in either direction — failing to file when you should, or filing without adequate reasoning —...

A Compliance Monitoring Programme is one of the most powerful tools a regulated firm has. It is also one of the most consistently underused — and the FCA's supervisory findings show that the regulator is increasingly...

A Section 166 skilled person review is one of the most significant regulatory interventions an FCA-regulated firm can face. It is not a routine supervisory visit. It is a deep, independent examination of your firm's...

Sanctions compliance is no longer a back-office checkbox. With OFSI issuing significant monetary penalties, the FCA embedding sanctions risk into its supervisory framework, and the geopolitical landscape producing new...

Every FCA-regulated firm and payment service provider subject to the Money Laundering Regulations 2017 must have a Business-Wide Risk Assessment. Not a summary. Not a policy statement. A documented, evidenced, and...

When a Senior Manager leaves a regulated firm, retires, or moves role, the accountability they carried does not simply transfer with their laptop and access credentials. Under SMCR, handover is a regulated event — and...

The FCA's expectations around vulnerable customers have never been more explicit. Under Consumer Duty, identifying, recording, and appropriately supporting customers in vulnerable circumstances is not a discretionary...

Under SMCR, the FCA's Conduct Rules apply to virtually every individual working in a regulated firm. When a potential breach is identified, what happens next is not a matter of internal discretion — it is a regulated...

If you're a Senior Manager, MLRO, or Compliance Officer working inside an FCA-authorised firm, you already know that SMCR isn't just a box-ticking exercise — it's a personal accountability regime with real criminal and...

Submitting a Senior Manager Function application to the FCA sounds straightforward. In practice, it's one of the most consequential regulatory processes a firm will go through — and one where mistakes, omissions, or...

Replacement business is one of the oldest conduct risks in financial services — and one that continues to generate regulatory findings, redress requirements, and in serious cases, enforcement action. The FCA has been...

Outsourcing a function doesn't mean outsourcing the responsibility for it. That's one of the most important — and most frequently misunderstood — principles in FCA regulation. Yet every year, firms face supervisory...