Can existing compliance frameworks be reviewed or improved?

Yes. Many firms periodically review their compliance framework to ensure it remains aligned with evolving FCA expectations. A framework review typically assesses whether existing policies, governance structures and monitoring programmes remain appropriate for the firm’s size, activities and regulatory permissions.

When should a firm develop its compliance framework?

Compliance frameworks should be developed before FCA authorisation and implemented before the firm begins regulated activities. Firms must demonstrate to the FCA that they have appropriate systems, controls and governance arrangements in place from the start of their operations.

FCA Compliance Frameworks
& Policies

FCA Compliance Frameworks & Policy Development

We provide specialist support to help firms design and implement robust FCA compliance frameworks and regulatory policies.

FCA-regulated firms must maintain clear governance arrangements, documented policies, and effective systems of internal control. These requirements are set out within the FCA Handbook.

The FCA expects firms to demonstrate that compliance is embedded throughout the organisation. This includes appropriate policies, monitoring procedures, risk management controls and clear senior management accountability.

Our role is to help firms establish compliance frameworks that are structured, proportionate and aligned with FCA expectations.

Developing FCA Compliance Policies & Procedures

Compliance policies form the foundation of a firm's regulatory framework. These policies & procedures set out how the firm manages risk, protects customers and clients, and complies with FCA rules.

We help firms to review, draft and enhance policies and procedures, ensuring they are practical, current and embedded into day-to-day business operations.

We support firms in drafting and implementing key compliance policies, including:

Compliance manuals.
Conflicts of interest policies.
Conduct risk frameworks.
Financial crime and AML policies.
Complaints handling procedures.
Consumer Duty frameworks.
Outsourcing policies.
Data protection and governance policies.

Each policy is tailored to the firm's business model and regulatory permissions rather than relying on generic templates.

Building a Structured Compliance Framework

A strong compliance framework brings together policies, procedures and governance arrangements into a clear operating structure.

We help firms design and implement compliance frameworks aligned with FCA expectations and the firm’s business model. These frameworks typically include:

Documented compliance policies and procedures.

Defined governance structures and reporting lines.
Risk management and internal control systems.
Compliance monitoring programmes.
Management information and regulatory reporting processes.
Training and awareness programmes for staff.

As part of the framework development process, we also help firms establish key compliance management tools, including a Compliance Plan and Compliance Monitoring Programme to provide effective oversight of regulatory risks.

We also support firms in developing and maintaining key risk assessments, including:

Business-wide risk assessments (BWRA)
Financial crime risk assessments
Market abuse risk assessments (where applicable)
Consumer Duty-related risk and outcomes assessments

This structured approach helps firms clearly demonstrate how compliance risks are identified, managed and monitored across the organisation.

Monitoring Programmes

The FCA expects firms to monitor the effectiveness of their compliance framework on an ongoing basis.

We help firms design risk-based compliance monitoring programmes that allow them to test whether policies and procedures are working as intended.

This typically includes:

Monitoring plans aligned with key regulatory risks.
Periodic testing of controls and procedures.
Documentation of findings and remediation actions.
Reporting results to senior management.

A structured monitoring programme helps firms identify issues early and demonstrate effective oversight.

Governance and SM&CR Alignment

Compliance frameworks must align with the Senior Managers and Certification Regime (SM&CR).

We support firms in establishing governance structures and control arrangements that clearly define responsibility and accountability, enabling effective senior management oversight.

This includes:

Mapping senior management responsibilities.
Documenting governance arrangements.
Supporting Statements of Responsibilities.
Aligning compliance policies with SM&CR obligations.
Ensuring reporting lines are clear and effective.

This helps firms demonstrate strong governance and regulatory accountability.

Reviewing Existing Compliance Frameworks

Many firms already have policies and procedures in place but need to ensure they remain aligned with evolving FCA expectations.

We provide independent compliance framework reviews to assess whether your current documentation and controls remain appropriate.

Our reviews typically assess:

Existing compliance policies.
Governance arrangements.
Risk management processes.
Compliance monitoring programmes.
Regulatory reporting controls.

Where improvements are needed, we provide practical recommendations to strengthen the framework.

Direct FCA Compliance Support

We provide practical, hands-on support when designing and implementing compliance frameworks. We work closely with your senior management and compliance teams to ensure your policies and internal controls are properly structured.

Our approach focuses on creating compliance frameworks that are not only aligned with FCA requirements but also practical for day-to-day business operations.

By supporting firms through the development and implementation process, we help ensure your compliance framework is clear, effective and ready for regulatory scrutiny.

Support for New and Established Firms

We support a wide range of FCA-regulated firms, including:

Consumer & wholesale investment firms (i.e. advisory, asset managers, hedge funds)
Insurance firms, including insurance brokers and managing general agents (MGAs)
Payments and e-money firms
Consumer credit firms
Cryptoasset firms requiring FCA authorisation
Fintech firms and startups

Our support is always tailored to the firm’s regulatory permissions, structure and business activities.

Frequently Asked Questions

FCA Compliance Frameworks & Policies

An FCA compliance framework is the system of policies, procedures and internal controls a firm uses to ensure it meets its regulatory obligations. It typically includes compliance policies, governance structures, monitoring programmes, risk management processes and reporting arrangements. The framework helps demonstrate that the firm operates in line with the FCA Handbook and manages regulatory risk effectively.

While requirements vary depending on the firm’s activities, most FCA-regulated firms are expected to maintain core compliance policies such as: • Compliance manuals • Conflicts of interest policies • Complaints handling procedures • Financial crime and anti-money laundering policies • Conduct risk policies • Consumer Duty frameworks • Outsourcing policies • Data protection and governance policies These policies should reflect how the firm actually operates and be regularly reviewed.

Speak to Us About FCA Compliance Frameworks

Developing a strong compliance framework is a key requirement for FCA-regulated firms. It ensures regulatory obligations are met while supporting effective governance and risk management.

If you need support developing FCA compliance policies or strengthening your firm’s regulatory framework, we can help.

Contact us to discuss your compliance requirements and how we can support your firm.

info@complianceangle.co.uk