Specialist Screening for Regulated Financial Services Roles.
Financial services firms need reliable information when assessing whether individuals appointed to regulated and senior positions are fit and proper for their responsibilities.
Conflict International provides specialist SMCR Screening and FCA Vetting Services for FCA-regulated firms requiring background verification for Senior Managers, Certification staff and other relevant appointments.
Our screening programmes can combine regulatory-reference checks with employment, identity, qualification, financial, criminal-record and other relevant verification according to the role and the firm's requirements.
Screening can be managed as an individual senior appointment or as part of an ongoing programme through our online vetting portal.
For a detailed explanation of the regime, the roles it covers and how fitness and propriety assessments work, read our guide to SMCR screening and FCA vetting.
Under the Senior Managers and Certification Regime, firms have responsibilities for assessing the fitness and propriety of individuals performing relevant functions.
The FCA's principal fitness and propriety criteria include:
Background screening can help establish factual information relevant to those assessments.
It does not determine whether somebody is fit and proper. That judgement remains the responsibility of the regulated firm, taking account of the individual's role, circumstances and the applicable FCA requirements.
Screening may be relevant when appointing or reviewing individuals performing:
Certification staff are not individually approved by the FCA in the same way as Senior Managers. Firms are responsible for assessing and certifying relevant individuals as fit and proper when appointed and at least annually thereafter.
The precise screening requirement should therefore reflect the individual's function rather than applying the same checks to every employee within a regulated firm.
Regulatory references are a particularly important part of SMCR recruitment.
For relevant appointments, firms must take reasonable steps to obtain appropriate references from the individual's current employer and employers during the previous six years.
The purpose is different from a conventional employment reference.
A regulatory reference may provide information relevant to a firm's assessment of the individual's suitability for a regulated function, including specified conduct, disciplinary or fitness and propriety information where the FCA rules require disclosure.
Conflict International can help coordinate regulatory-reference requests as part of the wider screening process.
The hiring firm remains responsible for meeting its FCA obligations and determining how the information should be considered.
Employment verification can supplement regulatory references by independently checking material elements of the candidate's stated professional history.
Depending on the screening scope, this may include:
A discrepancy does not necessarily indicate misconduct.
Where information differs from the candidate's application, the relevant facts should be established and considered in context.
Confirming identity provides the foundation for subsequent background checks.
Screening may include verification of appropriate identity documents together with the relevant UK Right to Work process.
Our specialist ID Verification & Right to Work Checks can be incorporated into an SMCR screening programme where required.
Criminal-record screening may be relevant to certain regulated appointments.
For applications to perform FCA-designated Senior Management Functions, firms are required to obtain the fullest criminal-record information that they are lawfully able to obtain under the applicable legislation as part of their assessment.
The appropriate criminal-record check for other positions depends on legal eligibility and the responsibilities of the role.
Conflict International can coordinate DBS Checks where the appropriate eligibility requirements are met.
The existence of a criminal record does not automatically mean an individual is unsuitable. Relevance, seriousness, circumstances and the passage of time may all need to be considered.
Financial soundness is one of the FCA's principal fitness and propriety considerations, but it should not be reduced to a simple credit score.
Where proportionate to the role, screening may identify relevant factual financial information such as:
Our Employee Credit Checks can be incorporated where financial screening is appropriate and lawfully justified.
Financial difficulty does not establish dishonesty or lack of integrity. Any findings should be considered in their proper context.
For positions requiring particular expertise, professional standing or regulatory qualifications, claimed credentials can be independently verified.
Checks may include:
Independent verification can help identify inaccurate, incomplete or unverifiable claims before an individual assumes a regulated or senior position.
Depending on the role, screening may also consider relevant information concerning:
These checks can help identify information that may require further consideration by the employing firm.
A company association, allegation or historic dispute should not automatically be treated as evidence of misconduct.
For appropriate appointments, additional online screening may be proportionate where information could be relevant to fitness and propriety, conduct or reputational considerations.
Our specialist Social Media Checks can be incorporated into wider screening where there is a defined and appropriate purpose.
Findings should be assessed for relevance and context rather than treating every piece of online information as material to the appointment.
Senior financial-services appointments frequently involve candidates who have worked or lived across several jurisdictions.
Conflict International can coordinate international checks relating to:
There is no single international database containing a complete regulatory or employment history.
The scope and availability of information varies between jurisdictions, and we will identify where records cannot lawfully or reliably be obtained.
SMCR screening can form part of a broader Pre-Employment Screening programme.
This can be particularly useful where a firm needs to combine regulatory vetting with identity, employment, qualification, Right to Work, credit, criminal-record or international checks through one screening process.
The appropriate package can be configured according to the function and level of responsibility rather than applying an identical screening programme to every candidate.
Conflict International's online vetting portal enables regulated firms to manage individual and ongoing screening applications from candidate submission through to completion.
Authorised client users can:
For firms managing regular recruitment or periodic screening, the portal can provide HR and compliance teams with greater oversight of the vetting workflow.
We can provide a demonstration when discussing your screening requirements.
SMCR obligations do not necessarily end when an individual is appointed.
Firms are required to assess Certification staff as fit and proper at least annually, and changes in circumstances may also need to be considered where relevant.
Additional screening may therefore be appropriate where:
Any repeat checks should remain necessary, proportionate and appropriate to the individual's role.
Conflict International supports financial services firms requiring screening for Senior Managers, Certification staff and other appropriate regulated appointments.
Whether you require a single senior appointment or an ongoing screening programme, we can configure the checks around the role, jurisdictions involved and your firm's screening requirements.
Tell us the positions being screened, anticipated volumes and checks required, and we can discuss the appropriate scope and provide pricing.
Complete the enquiry form below to discuss your SMCR Screening and FCA Vetting requirements or request a demonstration of our online vetting portal.
