Under the Senior Managers and Certification Regime (SM&CR), firms must conduct a DBS (Disclosure and Barring Service) check when registering individuals for Senior Manager Functions on the FCA Register. This check forms part of the application process, helping firms ensure that Senior Managers are fit and proper to hold these critical positions.
While it’s not mandatory to perform DBS checks on Certified Persons, such as Advisers, firms can opt to do so to strengthen their due diligence processes. Including a DBS check as part of the fitness and propriety assessment for Certified Persons provides an added layer of assurance regarding an individual’s background, enhancing the firm’s overall commitment to integrity and customer trust.
Each firm may determine what’s appropriate based on its policies and level of risk tolerance. By proactively including DBS checks, firms can bolster confidence in their team’s commitment to upholding high standards.
