Expert Support for FCA Regulatory Interventions

Regulatory interventions rarely come with the luxury of time. The Financial Conduct Authority (FCA) has a wide array of measures at its disposal, including Own-initiative Powers (OIREQ and OIVOP), Voluntary Requirements (VREQ or VVOP), product interventions, withdrawal of financial promotions, attestation requests, and—most disruptively—Dawn Raids. While each intervention requires the FCA to satisfy certain conditions, dealing with them usually follows a similar pattern.

When the FCA raises questions about your application for permissions, change in control, or issues notices such as VREQs or Sections 165/6, your day-to-day operations cannot afford to pause. With over 40 years of combined experience, Grønblad provides the knowledge and expertise to respond swiftly, ensuring your business remains compliant while continuing to operate smoothly.

We act as your trusted partner, helping you formulate initial responses, scope and manage required actions, and providing the temporary resources you need to make informed decisions under pressure.

If you need FCA regulatory intervention support, schedule a consultation call with us today.

The Importance of a Structured Intervention Response

An intervention response plan should be part of every firm’s normal compliance framework. By having a clear strategy, you can maintain control and engagement with the FCA from the outset. Below are some key considerations for handling interventions effectively:

  1. Initial Response
    Respond quickly and accurately, conveying full disclosure and cooperation. It is common to seek legal counsel and respond as vaguely as possible, but this approach can lead to a confrontational dynamic. A clear, forthright reply often paves the way for a more constructive dialogue.

  2. Stakeholder Engagement
    If the notice impacts other stakeholders—such as brokers, agents, or appointed representatives—inform both them and the regulators as early as possible to ensure they are properly included.

  3. Appropriate Legal Support
    Depending on the nature of the notice, you may need to work with both internal and external counsel. Legal guidance can be invaluable in complex or sensitive scenarios.

  4. Marketing & Public Disclosure
    Certain interventions (e.g., an OIREQ) will be made public through a First Supervisory Notice, and a VREQ may appear on the company’s page within the FCA Register. Plan your communications carefully to manage reputational impact.

  5. Expert Assistance for Investigations & Remediation
    It may be prudent to use different firms for the investigative phase and the remedial phase, as combining both can sometimes present conflicts. Leveraging specialists like Grønblad ensures you receive the best support at each stage.

  6. Documenting, Recording and Evidencing
    Maintain meticulous records of all communications, actions, and decisions. Clear documentation can significantly streamline the process and demonstrate your firm’s diligence.

How We Help During Regulatory Interventions

At Grønblad, we understand that every minute counts when you are under FCA scrutiny. Our proactive approach ensures you stay ahead by addressing concerns swiftly and effectively. Below are some of the ways we can support you:

1. Midflight FCA Application Support

If the FCA responds to your application with numerous questions or recommends withdrawal, it can feel like a critical setback. In many cases, the consulting firm that initially handled the application may not offer the level of support you need to resolve these queries.

A robust and complete application should minimise the risk of midflight FCA intervention. If you face this scenario, Grønblad helps you course-correct swiftly, ensuring your application remains on track. We guide you in formulating the right responses and planning any remedial work so that your day-to-day operations can continue smoothly.

2. Section 166 (s166) Assistance

The phrase “we’re going through a 166” can sound daunting, but it’s important to recognise that these reviews—once primarily part of the FCA’s enforcement regime—are now an extension of its approach to supervision. While the process can be intrusive, a s166 often ends up improving your business by identifying areas for enhancement.

When the FCA issues a Draft Requirement Notice under s166, the steps can be time-consuming:

  1. Acknowledge Receipt: Let the FCA know you have received the Draft Requirements Notice.

  2. Review the Notice: Understand its scope and objectives thoroughly.

  3. Select a Skilled Person: You may need to propose a suitable candidate or firm for the review if the FCA has not already appointed one. Do not feel constrained to only the relevant Lot on the FCA’s Skilled Persons Panel; instead, find the best fit for your specific circumstances.

  4. Engage with the FCA: Maintain open, transparent communication. If anything is unclear—or if you have concerns about the skilled person—discuss it with your case officer.

  5. Prepare for the Review: Collate all relevant documents, data, and other information.

  6. Facilitate the Review: Cooperate fully with the Skilled Person, providing prompt access to data and staff interviews.

  7. Review Findings: Once the Skilled Person completes their review, carefully consider the outcomes and recommended actions.

  8. Implement Changes: Address any identified issues and follow through with remedial steps. Be mindful if the same firm conducting the review offers remediation services, as this can lead to conflicts of interest.

  9. Submit the Report: Ensure the Skilled Person’s final report is submitted within the agreed timeframe.

Grønblad simplifies this entire process. We know the strengths and weaknesses of numerous Skilled Persons—who will best suit your industry and particular challenges—and we can guide you in making the right choice. While we will not serve as your Skilled Person, we will ensure you have the best possible partner for the job, helping you achieve a faster, more effective resolution.

Facing FCA Scrutiny? Let Grønblad Guide You

Regulatory interventions don’t have to derail your operations. With Grønblad’s expert support, you can respond confidently and maintain momentum. Whether you are dealing with midflight FCA applications, s166 Skilled Person requirements, or other FCA interventions such as OIREQs, VREQs, or Dawn Raids, we provide the clarity, structure, and strategic direction you need to navigate the process successfully.

Schedule a consultation today to ensure your firm is prepared to handle FCA interventions with confidence.

Why Choose Grønblad for FCA Interventions?

  • Rapid Response: We understand that FCA interventions demand immediate action. Our experience allows us to respond quickly, minimising disruption to your business.

  • Proactive Guidance: We don’t just react – we help you stay ahead by providing strategic advice and ongoing support.

  • Industry Expertise: Our deep knowledge of regulatory processes ensures that you are matched with the best resources for your specific situation.

  • Seamless Operations: With Grønblad by your side, you can focus on running your business while we handle the complexities of FCA intervention.

Why Choose Grønblad?

  • Grønblad combines the expertise of a large consultancy with the personalised attention of a boutique firm. Since 2016, we’ve built a reputation as a discreet, trusted partner for businesses worldwide. Our clients value our commitment to providing bespoke solutions, our deep regulatory knowledge, and our ability to deliver cost-effective support without compromising on quality.

    Our team’s diverse background enables us to approach each application with a comprehensive perspective, ensuring every detail is considered. Our mission is to make AML registration and compliance as smooth and straightforward as possible, allowing you to focus on your core business activities.

  • In addition to new authorisations, we support firms with:

    • FCA Authorisation Applications: Guiding you through the FCA Authorisation process.

    • Variation of Permission (VOP): Adding or modifying regulated activities.

    • Change in Control (s178 Notices): Seamless handling of ownership or control changes.

    • SM&CR Compliance: Preparing senior managers for FCA interviews (SMF1, 3, 16, 17) and ensuring fitness and propriety assessments are met.

    Need authorisation beyond the UK? We provide licensing support in:

    • Germany (BaFin): Expert native speakers to guide you through the BaFin process.

    • The Netherlands (AFM and DNB): Navigating Dutch regulatory requirements with confidence.