A number of Financial Conduct Authority (FCA) authorisation applications have been rejected based on the presence of a `SIF-for-hire’ (Significant Influence Function-for-hire’) in the application documents. These can be lawyers, accountants, or consultants.
The FCA has previously stated that “sometimes firms choose to get compliance support from external advisors such as lawyers or compliance consultants”. However, if this is your firm’s only Money Laundering Reporting Officers (MLRO) or compliance resource, the FCA frowns on this and “will probably refuse your application”. The FCA expects firms to have individuals who are permanent, amongst other requirements.
The FCA will cross-check the back history of the MLRO or Head of Compliance applicant during the `fit and proper assessment’ and will have a good look at where they have worked and for how long.
If the FCA perceives this person to be a `gun for hire’, you can expect the authorisation application to fail.
If you still feel you want to go ahead and apply for authorisation or registration, please contact us.
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