Skilled Person Reviews

Skilled Person Reviews are a supervisory tool used by the FCA and PRA to obtain an independent assessment of a firm’s regulatory framework.

Typically, s166 Skilled Person reviews are requested by a regulatory authority when they have concerns about aspects of a firm’s systems and controls. At Thistle Initiatives, we appreciate that this can feel overwhelming and daunting. Our approach to conducting Skilled Person reviews focuses on open and transparent communication, delivering timely and quality outputs our clients can rely on, and providing proportionate recommendations to support firms in enhancing their systems and controls.

Our team brings a wealth of sector and subject matter-specific knowledge, enabling us to tailor each review to the unique challenges faced by individual firms, to foster sustainable improvements and greater regulatory confidence.

Financial crime compliance is under intense regulatory scrutiny. At Thistle Initiatives, we help firms act swiftly and respond with confidence.

Our experts deliver audits, advisory, and managed resources that are fast, practical, and effective. With former regulators and industry specialists on our team, we bring experience from multiple sectors and major enforcement programmes. We combine deep regulatory expertise with commercial insight, tailoring solutions to each client’s business model, risk profile and maturity.

We’re here to solve complex financial crime challenges and keep your operations moving.

Jessica Cath
Partner, Financial Crime

Our Process

Thistle Initiatives is focused on financial crime and regulatory compliance. Our people are our strength, with not only significant Skilled Person review experience, but also former in-house compliance staff and regulators. This allows us to provide not only practical Skilled Person experience, but also regulatory insight and a pragmatic and sensible approach in assessing frameworks and providing proportionate recommendations when necessary.

Acting as the Skilled Person

We are part of the Association of Professional Compliance Consultants (APCC) Additional Skilled Person Suppliers List, providing firms with the confidence that our expertise and reliability can be trusted upon.

Our approach is fair, independent and proportionate to firm’s business model, risk profile and maturity. Although we utilise a structure which follows an approach developed utilising Partners’ significant experience in delivering Skilled Person reports, we appreciate that each firm is different, and tailor our approach to ensure it meets specific needs, as well as the regulator’s requirements.

Firm-side Skilled Person Support

A Skilled Person review requires strong and experienced project management. From delivering presentations to the Skilled Person, handling communications and a significant number of requests, as well as challenging findings and recommendations, having an independent assessment of a firm’s controls goes beyond scrutiny of documentation.

Effective engagement and timely management of a Skilled Person review can ensure firms receive a Report which is accurate and adds value.

Thistle Initiatives has the experience to support firms with the administrative burden so that your business does not come to a halt during the review.

How We Help our Clients

CASE STUDY: Skilled Person Review: Strengthening DB Transfer Advice Compliance

Challenge

The Firm faced significant regulatory risk due to weaknesses in its Defined Benefit (DB) transfer advice process. Issues included poor client fact-finding, flawed TVAS assumptions, inadequate suitability reports, and weak audit trails. These failures created a high likelihood of unsuitable advice and potential customer detriment.

How we helped

Thistle acted as Skilled Person under s166 FSMA, reviewing 38 months of DB transfer advice. We identified the review population, managed client opt-ins, assessed advice using FCA-approved tools, and implemented a robust redress methodology. Our team delivered structured QA, regular reporting to the Firm and FCA, and clear recommendations for process improvements.

Outcome

686 cases reviewed; 173 required full assessment
146 cases unsuitable; 65 had no financial loss
£969,256.21 paid in redress to affected customers
Clear recommendations implemented, strengthening systems and controls, improving compliance, and reducing future risk

Read the full case study here.

Our Supervision and Enforcement Support

Skilled Person Reviews sit within our wider Supervision and Enforcement support. We help firms address:

Early supervisory concerns
Potential or emerging Section 166 triggers
Formal Skilled Person appointments
Post‑review remediation
Issues that may attract enforcement attention

Our support is calm, practical and grounded in extensive regulatory insight. We help firms understand the root cause of issues, prepare for regulatory engagement and implement workable remedial action.

Get in touch

Michael Knight-Robson
Partner, Financial Crime

Michael Knight-Robson 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.

Given Michael’s extensive Skilled Person review experience, he leads Thistle Initiatives’ Skilled Person framework, ensuring reviews are delivered in line with regulatory expectations. His expertise in the space means Michael conducts Financial Crime (Lot E) and Market Abuse (Lot F) reviews that meet regulatory expectations.

Our Expertise

Lot B

Lot C

Lot D

Lot E

Lot F

Lot I

Lot P