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Employment screening under the Senior Managers and Certification Regime

Since 2019, all FCA regulated firms have been governed by the Senior Managers and Certification Regime (SM&CR), a framework designed to uphold both individual accountability across leadership and organisational integrity within the UK financial market.

This framework guides the structure to which boards and managers operate, ensuring those in senior roles have the skills, knowledge, and integrity to act in their customers’ best interests, and to apply a standard of personal conduct to everybody working in financial services.

Declan Bamber, Screening Account Manager at Conflict International advises: “Since the roll-out of SM&CR, employment screening has been at the forefront of regulatory compliance.

“Professional misconduct can result in steep penalties, compounded by reputational damage leading to a loss of business. Compliance is therefore critical, but demand for skilled staff means firms are also under pressure to recruit and promote quickly – so hiring managers must have the mechanisms in place to carry out background checks both quickly and effectively.”

Screening under SM&CR ensures that individuals placed in roles within its framework are appropriately vetted, and that firms can confidently certify that senior staff are ‘fit and proper’ to carry out their roles. Screening requirements differ based upon the function of each role, so it is necessary to have a process in place to ensure the correct checks are carried out for both senior managers and certified persons.

Conflict International works with firms to ensure appropriate screening process is in place once the definitions of responsibility have been agreed.

Screening packages may include:

Senior Managers Screening

  • Adverse credit search
  • ID verification
  • Standard DBS
  • 6-year occupational history including regulatory referencing (where applicable)
  • Gap analysis
  • Highest level education verification
  • Professional qualification check
  • Directorship search
  • Compliance database search
  • Adverse Media check 
  • PEPs & Sanctions check
  • FCA check
  • Annual rescreen comprising adverse credit search, standard DBS, PEPs and Sanctions, Adverse Media check, FCA check, Directorship search.

Certification Screening

  • Adverse credit search
  • ID verification
  • Basic DBS
  • 6-year occupational history including regulatory referencing (where applicable)
  • Gap analysis
  • Highest level education verification
  • Professional qualification check
  • Directorship search
  • PEPs & Sanctions check
  • FCA check
  • Annual rescreen comprising adverse credit search, basic DBS, PEPs and Sanctions, FCA check, Directorship search.

Contact Declan Bamber to review your screening process in line with the SM&CR regime and discuss how Conflict International can help you.

When you have suspicions that something isn’t quite right, our experts can help you get to the truth.



To discuss how we can assist with an issue, contact us now in confidence.

Call our Head Office on +44 (0)20 7917 2939 or email our team.