Compliance resource

Past Business Reviews

The FCA’s approach to supervision over the past few years has increased the need for past business reviews. Some sectors have seen this grow and it has become a standard part of regulation within the industry where as other sectors are just now starting to see the increase of FCA supervisory visits leading to a need of assurance audits and past business reviews.


Our Auditing and Past Business Review and Remediation services provide clear, sampling and quality assurance methodologies which are in line with regulatory expectations.


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Compliance Support Services Explained


The scope of regulatory assurance audit consists of assessing whether a firm continues to satisfy the FCA’s standards and industry best practice. Firms should seek to assess the suitability of the processes and arrangements which are in place such as:


  • Regulatory reporting, notifications (e.g. changes in approved person’s details, change in control notifications etc.) and the maintenance of up to date standing data/firm details (effective supervision).
  • Oversight over the ongoing solvency of the firm and appropriate provisions against liabilities (e.g. legal liabilities that may arise as a result of misconduct) (appropriate financial resources).
  • Oversight of the firm’s training and competence process for staff involved in the conduct of the regulated activities (appropriate human resources).
  • Oversight of the firm’s quality assurance process to ensure that staff are demonstrating conduct that complies with the training provided and equally complies with the requirements under the regulatory system (appropriate human resources).
  • The operations/suitability of the firm’s ‘three lines of defence’ regulatory shield, namely risk assessment, compliance (risk control) and internal audit (compliance monitoring). We will also review the governance structure that supports the firm’s systems and controls (i.e. regulatory risk management framework).
  • The appropriate use of IT systems to support the conduct of the regulated activities (if applicable). This will consist of examining the typical audit trail provided on the IT system (e.g. CRM systems) to establish adequacy.


Get our help with auditing and past business reviews


Our audit methodology consists of conducting an adequacy assessment of a firm’s policies, procedures and supporting documents to establish whether a firm’s documented compliance framework meets the requirements under the regulatory system. This is supported by conducting an interview with select members of the firm’s senior management team to ascertain representations of a firm’s processes in practice (supported by, where appropriate, inspecting sample records).


We produce written feedback by way of an audit report where we identify areas that require improvements and set out recommendations to the firm.


Our team of dedicated professionals conduct a range of services which are tailored to your budget from remote regulatory assurance audit to full scope regulatory assurance audit.


Get in touch with us now to discuss your regulatory assurance auditing and past business reviews.


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