For individuals applying to perform Senior Management Functions, firms must obtain a standard criminal record check through the Disclosure and Barring Service (DBS) as part of the FCA approval process. This requirement helps ensure that both the firm and the regulator are aware of any matters that may affect an individual’s suitability to hold such a position of responsibility.
Although DBS checks are not mandatory for individuals who fall within the Certification Regime (e.g. Mortgage Advisers), many firms choose to include them as part of their wider Fit and Proper assessment process. Taking this additional step can provide greater assurance that individuals meet the standards expected within the financial services sector.
Importantly, a criminal record check should not simply be viewed as a compliance exercise. Instead, it should form part of a broader assessment that considers honesty, integrity, financial soundness, and professional competence. Where issues are identified, firms should consider the nature, severity, and relevance of the matter to the individual’s role before making a decision.
In practice, many firms find that having a clear and consistent approach to DBS checks strengthens their recruitment and governance processes. It demonstrates that the firm is taking reasonable steps to understand the background of individuals performing regulated roles and supports the broader objective of maintaining trust and confidence within the financial services industry.
