What are the FCA Compliance Arrangements? - Know Your Compliance Limited

If you are applying for FCA authorisation, you will definately have wondered “what are the FCA compliance arrangements?” These are referred to in the application form and supporting authorisation application guidance notes. In their reference to these compliance arrangements, the regulator advises that ‘when assessing your application, they need to be satisfied that you have the appropriate compliance arrangements in place to meet your regulatory obligations’. This is the case both during the application process and on an ongoing basis.

The arrangements for compliance are the policies, procedures and controls you have in place to ensure compliance with the FCA Handbook and relevant legislation. They may vary dependant on the size, scope and type of business you run/work for. There can also be specific FCA policies and controls required for certain regulated activities.

However, as a minimum, you will need to have policies and controls in place that cover the below areas and criteria. These are the sections listed on the FCA application guidance notes that will accompany your authorisation submission. Thsi list is not exhaustive and may vary based on business size and type.

Complaint Handling Program
Anti Money Laundering Program
Policies and controls for assessing and evidencing senior management and relevant employee skills, knowledge and expertise
Business continuity arrangements
Senior Manager Certification Regime and/or Fit and Proper controls and checks for SMF/approved persons
Policies and monitoring on all communication with customers materials
Conflicts of Interest Policy and Procedures
TCF, Vulnerable Customers and Protecting Customers’ Interests policies and controls
Consumer Duty Compliance Program
Distance Marketing and Financial Promotion policies and procedures
Due diligence and Customer identification procedures
Audit and monitoring controls and procedures.