SMCR and Employment Screening


The SMCR (Senior Managers and Certification Regime) applies to all firms who are authorised under the Financial Services and Markets Act
The SMCR applies to all UK-incorporated banks, building societies, credit unions and Prudential Regulation Authority-regulated investment banks and insurers.

As of the 9 December 2019, it has been expanded to cover firms that are currently regulated by the FCA. This will affect an estimated 50,000+ asset managers, brokers and consumer companies.
At CV Insight Ltd, we are working with clients to advise how firms can introduce Employment screening to assess whether an individual can be considered ‘fit and proper to perform a role’ in the context of the SMCR.

SMCR Criminal Record Checks – Senior Managers

Under the SMCR It is a requirement that individuals who are going to occupy a Senior Management Function undergo a standard criminal record check (which details both spent and unspent convictions). It is also a mandatory requirement that Non-Executive Directors who are NOT occupying Senior Management Functions are subject to a criminal record check; however, they are only eligible for a basic DBS (not a standard) check.

SMCR Criminal Records Checks – Certified Persons

Criminal records are not a requirement for individuals occupying a Certification function however the FCA has stated that firms may still choose to do so. Firms currently subject to SMRC require candidates for certified function roles to complete a Basic disclosure check which discloses details of unspent convictions Although basic criminal record checks can be undertaken at the firm’s discretion, they are common industry practice and considered invaluable for assessing an individual’s integrity.

Employment Referencing Under The SMCR

A company wishing to appoint a Senior Manager, Certified Person or Non-Executive Director must seek references from any business where that individual has worked in the last six years. Furthermore, where that business is regulated by the FCA and or the PRA, such references should be regulated references. Regulatory references should mirror the format

Typical Screening Checks for SMCR

At CV Insight we can assist you with the SMCR employment screening process and have outlined below popular screening packages we offer with other checks to consider.

We offer

    UK FCA Certified Persons (Non Controlled Functions)
    • Identity Document Algorithm Validation Check
    • Credit and Address Check
    • UK Directorship Check
    • UK Sanction/Anti-money Laundering Check
    • FCA Register Check
    • Highest Education Check
    • Professional Qualification/Membership Check
    • 6 Years Employment (capped 5 roles includes gap analysis over 90 days)
    • International Adverse Media Check
    • Basic Criminal Disclosure

    UK FCA & PRA Senior Manager Regime Package
    • Identity Document Algorithm Validation Check
    • Credit and Address Check
    • UK Directorship Check
    • UK Sanction/Anti-money Laundering Check
    • FCA Register Check
    • FCA Company Check
    • Highest Education Check
    • Professional Qualification/Membership Check
    • 6 Years Employment (capped 5 roles includes gap analysis over 90 days)
    • International Adverse Media Check
    • Standard Criminal Disclosure

    Contact us for more information