Complyport Specialises in providing governance, risk and compliance services

Complyport Specialises in providing governance, risk and compliance services

Skilled Person Reviews and Regulatory Investigations (Section 166)

Under section 166 of the Financial Services and Markets Act, the FCA has the power to require a report by a “Skilled Person” on specified matters related to a firm’s systems, controls, and failings. According to the FCA there are more than 50 such requests in any one year by the FCA.

“Skilled Persons” are independent persons/firms with the skills necessary to prepare a report on the regulatory matters that the FCA is concerned with in each case. The FCA maintains an approved “Skilled Persons Panel” for eight different regulatory areas (eg, client assets, financial crime, prudential) made up of well-known firms specialising and pre-approved by the FCA. Each firm on the Panel has gone through a very rigorous and stringent evaluation process by the FCA, and therefore the FCA feel more comfortable when firms choose Skilled Persons form that Panel.

Complyport is on the FCA’s Skilled Person Panel.

As a member of the FCA’s Skilled Persons Panel, Complyport has a proven track record of successfully handling various s166 assignments. These assignments cover a wide range of areas such as financial crime, governance, client assets, prudential matters, controls, and risk management frameworks. With our expertise and experience, Complyport is ideally positioned to be appointed as the Skilled Person responsible for preparing the required report in accordance with the Draft Requirement Notice (DRN) outlined in section 166(3)(a) of the Financial Services and Markets Act 2000 (FSMA). 

We have a thorough understanding of the requirements relating to regulated firms, in particular those relating to, Conduct of Business (COBS), Threshold Conditions (COND), Systems and Controls Sourcebook (SYSC) including SM&CR, Markets in Financial Instruments Regulation (MiFIR), Market Abuse Regulations (MAR) the UK legal and regulatory requirements regarding AML and CTF and the Supervision sourcebook (“SUP”). We understand the importance of robust management and conduct risk controls within regulated firms.

Over the years we have also carried out regulatory compliance and financial crime advisory assurance reviews for a wide variety of client firms in the retail and wholesale markets including:

  • firms involved in prime brokerage,
  • execution,
  • investment management,
  • fund management,
  • custodial services,
  • payment services and digital asset providers,
  • lending and consumer credit,
  • and more.
Complyport Approach

With the benefit of both our wide-ranging industry experience and extensive regulatory experience, Complyport is able to approach any section 166 engagement with an open mind, and in a practical and pragmatic manner.  Whilst the type of projects we take on vary, the key values of our approach are:


We assign a team of highly experienced experts suited to the regulatory requirement and your firm’s unique structure and circumstances.


Guided by our long experience with section 166 work, we are able to price accurately and provide a scope of work and budget based on the requirement notice to ensure we meet the objectives at a reasonable cost. 

Our experts will present you with findings from our review and highlight any areas of concern. You will have the opportunity to provide feedback prior to releasing the final report.


Complyport is a market leading consulting firm supporting the UK financial services industry for over 22 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.

Complyport advises and assists firms to become authorised and to comply with the rules and requirements of regulators on an ongoing basis. We have successfully assisted over 1000 firms to become authorised with the FCA and EU and are providing regulatory support to over 600 regulated firms on an ongoing basis globally. With presence in the UK and EU, as well as via our Associates Network, Complyport can assist firms across multiple jurisdictions.

We specialise in supporting the UK financial services industry with compliance guidance, advice and best practice including support with:

  • Internal Audit Function support
  • Operational resilience & cybersecurity advice
  • CASS advice and protections of client assets
  • Prudential support, IFPR, ICARA and financial resilience advice
  • Financial Promotions management software solutions
  • Comprehensive compliance work-flow management software
  • Compliance managed services and resourcing compliance personnel
  • Financial crime and forensics
  • Consumer Duty implementation advice
  • Skilled Person Reviews (S166) and regulatory investigation
  • Expert Witness
  • Anti-Money Laundering and HMRC Supervision
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