Once a Skilled Person review is commissioned, the countdown begins. Michael Knight Robson explores how firms can prepare methodically, present their frameworks clearly and show the supervisory maturity regulators expect.
"By failing to prepare, you are preparing to fail."
When this phrase was first coined, it is unlikely that the person was thinking about Skilled Person reviews. However, as ever with the case of liaising with regulatory authorities, it is paramount. The difference between a contained Skilled Person review and a prolonged supervisory scrutiny often lies in what happens before the Skilled Person begins their fieldwork.
As part of our ongoing series on navigating Skilled Person reviews, this latest insight follows on from Skilled Person Reviews: Responding To A Requirement Notice, where we detailed the steps firms should take once they have received a Requirement Notice. Once a firm has acknowledged the Notice, chosen the Skilled Person and mobilised internal resources, attention must now turn to the inevitable; the Skilled Person is coming, and being prepared for the level of scrutiny is vital in ensuring the review is successful.
A Skilled Person review is rarely just a technical exercise, and success is not always driven by the number of findings identified. It is an intense regulatory intervention that tests not only the strength of a firm’s controls, but its culture, transparency and maturity. Consequently, preparation must include:
- Internal coordination
- Presentation of the control framework
- Interview preparation for staff
- Identifying the unknown
Internal Coordination
A Skilled Person review should never be treated as a side task to BAU delegated to compliance. It is a firm‑wide regulatory exercise that requires formal governance, structured oversight and clear accountability.
Establishing Clear Ownership
Fragmentation is one of the biggest risks we see in reviews. Many firms manage this risk by appointing a central review lead. Skilled Person reviews can range from 12 weeks to 12 months, so firms should always be prepared to have a deputy on hand. Reviews are an intense exercise, and burnout is common when firms rely on one person.
Without a key point of contact for the Skilled Person and regulatory authority, multiple teams begin responding to information requests independently, documentation is shared inconsistently, and the biggest risk is that mixed messages on controls are communicated.
However, although many firms will identify a central review lead, as well as a deputy, too often firms will delegate this to an already stretched resource, which can lead to response delays. This can have devastating effects on the success of the review. To prevent this, firms should identify an individual with large-scale project management experience, or utilise external support to help firm-side Skilled Person engagement.
Importantly, this role is not administrative. It requires someone capable of identifying emerging themes, anticipating lines of enquiry, and managing internal sensitivities. The individual should:
- Define reporting lines to senior management and Board
- Establish a structured cadence of internal progress meetings, and
- Document decisions throughout the review for a clear audit trail.
Creating a Working Group/Steering Committee
Skilled Person reviews often extend beyond the immediate area of focus. For example, a financial crime review may broaden into governance, HR, IT, operations or outsourcing arrangements. A strong firm-wide regular meeting of key stakeholders will ensure:
- Subject matter expertise is available immediately
- Responses are accurate and aligned across the firm
- Documentation and information are gathered and provided efficiently
- Impacts on BAU are understood early to help mitigate the risk
There is a fine balance between prioritising BAU and a Skilled Person review. We often see the extremes of both: failing to prioritise Skilled Person work and falling behind on deadlines, or diverting too much BAU resource and creating new control gaps. Both the Skilled Person and Regulatory Authority observe behaviour as closely as they analyse documentation. Clear governance arrangements demonstrate seriousness and maturity. Conversely, disorganisation or visible internal disagreement may reinforce supervisory concerns. Preparation, therefore, is not only about logistics. It is about signalling control.
Presentation of Control Framework
Of course, the content and design of your control framework are the most important elements, but how you present it should not be underestimated. This can ultimately help firms prevent follow-up Skilled Person reviews and/or enforcement, both of which can be very costly.
Managing the Documentation Request
As part of mobilisation, the Skilled Person will issue a Request for Information (RFI) that sets out the documents they want to review. If the RFI is well structured, it will include both the document name and a short description. Because terminology varies across the industry, firms must be clear on what the Skilled Person is actually asking for. The RFI should also give firms space to record what has been submitted, when it was provided and any relevant commentary, which helps create a simple audit trail and helps both sides stay organised. At this stage, the firm should scrutinise the RFI carefully. First, check that each request is within the scope of the Requirement Notice. Second, make sure the request has been fully understood so the right document is supplied. Firms should not hesitate to question vague or out‑of‑scope items. When collating documents, firms should ask:
- Is the document current, and if applicable, approved by Senior Management/the Board?
- If approval was required, do you have the appropriate minutes documenting this?
- Does the document have any embedded appendices which will need to be extracted and provided?
Some firms will, depending on the timeline protocols set out by the Skilled Person, attempt to conduct a critical and independent assessment of the documentation prior to it being provided. There will be insufficient time to make any updates where gaps are identified, and any last-minute changes/updates will be picked up by the Skilled Person. The objective for the assessment prior to documentation being provided is to ensure the Firm fully understands the extent of any gaps and transparently presents these to the Skilled Person.
Walkthroughs
Walkthroughs are an important tool for a firm to set the tone and proactively acknowledge known weaknesses, and consequently, it is paramount that firms spend time and effort to ensure these are well presented, well-resourced and depict an accurate picture of the current state. If done poorly, they can lead to more questions than answers. Walkthroughs are a firm-led presentation that explains governance, risk management and the controls in scope. Again, the key people need to be in the room, so that those who lead the walkthroughs are those responsible for the systems and controls, and therefore, leaving all matters to Compliance is not the best approach. Each session should include a clear, tailored presentation that covers key processes, control ownership, governance structures and any areas that need improvement. Sharing the materials afterwards supports transparency and helps the Skilled Person follow the details. Walkthroughs need to be structured, documented and rehearsed. Presenting under scrutiny is challenging, and practice helps presenters stay clear and consistent. Rehearsals also test the flow and allow teams to anticipate likely challenges. Firms should ask:
- Do my walkthrough presentations flow naturally?
- Have we considered what questions the Skilled Person may ask?
- Have we got the right people delivering the presentations?
Interview Preparation
Strong design documentation and control effectiveness can be undermined by unprepared interviewees. Although Skilled Person interviews are rarely confrontational, they are direct, probing, challenging, risk-focused and designed to test consistency across staff. The way in which individuals respond can materially influence perceptions of competence, ownership and cultural tone. Many senior staff are not accustomed to structured regulatory interviews. Under pressure, individuals may:
- Over-explain and introduce risk unnecessarily
- Speculate when unsure
- Contradict documented controls and others
- Be defensive and do not take ownership of weaknesses identified
Consequently, firms must prepare individuals likely to be interviewed. Depending on the scope of the review, it will be fairly obvious who is likely to be interviewed, i.e. Head of Compliance, MLRO, C-suite members, etc. Mock interviews help them understand the format and practise clear, accurate responses. The Skilled Person will also interview less senior members of staff who are conducting controls on a daily basis. There is often limited time for individual coaching, so many firms run team‑based sessions to build consistency and avoid common pitfalls. Preparation sessions should:
- Simulate realistic lines of questioning
- Test knowledge of role responsibilities
- Explore how controls operate in practice
- Challenge responses for clarity and precision
Identifying the Unknown
A phrase we often hear before an audit or Skilled Person review is “we don’t know what we don’t know.” If a s166 Skilled Person review has been commissioned, the regulator has already found weaknesses. The Skilled Person will almost always uncover more, because their assessment goes deeper than the FCA’s initial visit and limited sampling. At this point, the aim is not to avoid findings but to avoid surprises.
Firms usually have circa six weeks between receiving the Requirement Notice and the start of fieldwork. Alongside mobilisation, one useful step is a short pre‑review assessment. It may feel unnecessary to review controls that will soon be examined again, but maturity and awareness matter as much as the framework itself. Showing the Skilled Person that the firm has identified weaknesses and built a clear remediation plan demonstrates ownership and reduces the risk of harsher consequences later.
Many firms, therefore, commission an independent, exceptions-based review of the controls in scope. A consultancy initially shortlisted by the Firm for the Skilled Person role but not selected is often a practical choice, particularly when timelines are tight. The firm should request a concise exceptions report highlighting any additional gaps not raised in the FCA’s initial feedback, with proportionate recommendations that can be translated into remediation actions, ready to be presented to the Skilled Person at the outset of the review.
Preparation as Cultural Evidence
Ultimately, preparation for a Skilled Person review is not about ‘managing optics’. It is about demonstrating that the firm:
- Is mature and takes ownership of past failings, with a clear motive to learn from the Skilled Person review and enhance its systems and controls
- Maintains effective governance
- Takes supervisory intervention seriously
The tone of a Skilled Person review is set early. Organisation, transparency and responsiveness shape how the Skilled Person interprets everything that follows. Firms that prepare with discipline and structure not only improve their chances of a contained outcome, but they also strengthen their control environment in the process. No firm has a perfect compliance framework. Resource pressures, changing expectations and evolving risks mean gaps will always exist. What matters is how the firm responds. Preparing methodically and calmly signals that the firm understands its risks and is committed to remediation and to building a sustainable, proportionate framework that meets regulatory expectations.
Meet the Expert
Michael Knight-Robson, Financial Crime Partner 
Michael has joined as a Partner in the Financial Crime team, working alongside Jessica Cath. With over 15 years’ experience in financial crime compliance, he was most recently a Director at BDO, where he built a strong reputation for leading s166 Skilled Person reviews and providing firms with proportionate, risk-based advice to stay compliant. His career also includes senior roles at Bovill, Lloyds Banking Group and Investec, giving him practical, well-rounded expertise to help firms strengthen their financial crime compliance frameworks.