INFORMATION YOU NEED. PEOPLE YOU CAN TRUST.

TRENDS REPORTTRENDS REPORTEMPLOYMENT SCREENING

Employment Screening in EMEAFinancial services and the FCA

2

CONTENTS

THE NEED TO SCREEN 4

Prevention is better than cure 4

What’s the worst that can happen? 5

The CV as a sales tool 7

Discrepancy Rates 13

COMPLIANCE 15

The Financial Conduct Authority 15

Current requirements and recommendations 17

Forthcoming changes 18

The Senior Managers Regime 19

The Certification Regime 20

Conduct rules 21

Regulatory references 22

Fraud and the UK Anti-Bribery Act 25

Best practice screening 26

Financial Conduct Authority (FCA) Final Rules on Regulatory References

31

Further Recommendations 33

Market comparison 34

SERVICE SUMMARIES 35

Verifications 35

CV / résumé comparison 35

Education and academic qualifications 35

Employment history 36

Professional credentials 36

Record/database checks 37

Adverse media 37

China bribery record 37

CIFAS general search 38

CIFAS staff fraud search 38

Consumer credit 39

Criminal record 39

Directorship 40

Financial regulatory 40

Global watch-lists and sanctions 41

Identity authentication 41

REFERENCE 42

Understanding UK criminal record checks 42

Understanding international criminal record checks 45

FCA mandatory reference request template 47

Financial regulatory authorities 48

Sources 52

WELCOME 3

3

WELCOME

We have created this report to provide insight for banking, financial services and insurance (BFSI) organisations into the background screening environment in EMEA (Europe, the Middle East and Africa), including the current screening environment and key compliance considerations. In particular, we consider the implications of the changes to the Financial Conduct Authority (FCA) and Prudential Regulation Authority requirements for fitness and propriety checks.

We hope you find this helpful as you conduct your own due diligence on employment screening solutions.

WHY CHOOSE FIRST ADVANTAGE?

At First Advantage, the key to our success and, therefore, the success of our clients’ is our winning combination of local knowledge and global reach.

Local knowledge

Global reach

clients

35,000background screens annuallyfor 17.2 million applicants

55 millionemployees

5,000offices in 13 countries

26

Welcome to our report on employment screening in EMEA

HQ in Canary Wharf, London, and Operational Centre in Colchester, Essex

Serving businessesin EMEA since 1984

Working with many ofthe UK’s largest employers, including many leading banks

4

THE NEED TO SCREEN

Prevention is better than cure

There are few industries where the risks of financial loss, fraud and corruption are higher than in financial services.

The impact of an administrative error or miscalculation can have significant knock-on effects, whilst the potential consequences of deliberate deception hardly bear imagining. It comes as no surprise then to find that financial services organisations conduct the widest range of checks compared with any other industry.

Financial institutions worldwide use background screening to prevent unsafe, under-qualified or otherwise unsuitable people from entering their companies and thereby reduce the likelihood of:

Fraud

Major fraud is almost always internal, as reported by CIFAS, the UK’s Fraud

Prevention Service (see page 7 for further information).

Negative publicity

This can be devastating and long lasting to a company’s reputation (see

pages 5 and 6).

Impact on staff performance

Loss of productivity and morale

Negligent hiring litigation

As several companies have recently discovered (see pages 5 and 6).

Increased staff turnover and recruitment costs

A typical screening costs less than 2% of the average cost to recruit a senior

manager*

* Depending on screening scope, a typical screening will cost $150-230 USD (c. £100-150 GBP) – a fraction of the $12,000 USD (c. £8,000 GBP) average cost to recruit a senior manager, as reported by the Chartered Institute of Personnel and Development.

5

THE NEED TO SCREEN

Ross Etherson, Midas Medical Recruitment, UKAs reported by The Telegraph

Midas Medical Recruitment has been found

guilty of faking doctors’ CVs, putting patients’

lives at risk. The CVs of locum medics were

‘embellished’ to enhance their experience and

bogus references were added.

The judge gave head-hunter Ross Etherson

a “wholly exceptional” two-year suspended

sentence and criticized NHS management for

failing to carry out basic checks.

Barry Meyer, Lorry Driver, UKAs reported by The Recruiter

A London haulage company is under

investigation for failing to perform adequate

employee checks, following the death of a cyclist

caused by one of its drivers, Barry Meyer. Meyer

was both unlicensed and uninsured and at time

of the incident.

Nick Denton, traffic commissioner for the South-

East and London Metropolitan area, commented

that the haulage company trusted “Meyer’s

verbal assurance that he had the right driving

licence” and “never bothered to check whether

this was really so.”

What’s the worst that could happen?

Ineffective screening can have significant consequences, as many recent news reports from around the world illustrate…

6

THE NEED TO SCREEN

Craig Taylor, Founder of Taylor Civil Engineering Ltd, UKAs reported by HR Grapevine

Taylor received a jail term earlier this year following his conviction for dishonestly making false representation to make a gain, amongst other offenses. The court heard that Taylor “lied about having a degree when he did not have one” and “also lied about having a previous conviction.”

Daniel Mthimkhulu, Chief Engineer with the Passenger Rail Agency of South Africa

As reported by Business Tech

Mthimkhulu was suspended and has subsequently resigned from Prasa following accusations of “gross dishonesty and fraudulent misrepresentation of his academic qualifications.”

He is alleged to have claimed an engineering degree from the University of the Witwatersrand (Wits). However, Wits said it did not have any record of Mtimkulu attending the university.

Hlaudi Motsoeneng, Chief Operating Officer with the South African Broadcasting Authority

As reported by News24

Motsoeneng is facing a range of misconduct charges, including gross dishonesty “for misrepresenting facts relating to his qualifications” and “misleading the SABC into believing he was once employed as Head of Communications at the Northern Cape tourism

department.”

Lifeguard, Cotswold Country Park and Beach, UKAs reported by The Telegraph

After 15-year-old Kajil Devi drowned at Cotswold Country Park and Beach in Gloucestershire, it emerged that a lifeguard on duty at the time had been hired by email and no checks had been carried out on her qualifications.

The employee had not been interviewed or asked for proof of her skills by staff. The operators of the resort have since been ordered to pay £250,000 in fines and costs.

7

THE NEED TO SCREEN

The CV as a sales tool

A CV (curriculum vitae) or résumé is the job seeker’s primary sales and marketing

tool – a means to promote themselves to your company. Unfortunately, like many

promotions, CVs are not always as they seem.

Numerous studies over recent years have shown the propensity of job seekers to

‘embellish’ their CVs or hide aspects of their past.

CIFAS | Fraudulent employment applications

CIFAS is the UK’s Fraud Prevention Service. Its ‘Internal Fraud Database’ contains

information on cases of confirmed fraud recorded by 134 member organisations.

Participating organisations exchange information relating to applications for products

and services where the applicant fails verifications checks and confirmed cases where

a member of staff has acted fraudulently. Members can then use the database to

check whether a candidate is confirmed as having committed a fraud against another

member organisation.

The CIFAS ‘Employee Fraudscape 2015’ report examines the data contained in the

Internal Fraud Database, which shows (all figures refer to 2014):

63% 88%of all recorded internal

frauds were fraudulent job applications

of all unsuccessful employmentapplication frauds were attemptsto conceal adverse credit history

of all successful employmentapplication frauds were

the concealment of unspentcriminal convictions

66%

8

THE NEED TO SCREEN

Definitions

Employment application fraud | where the individual intentionally deceived their

prospective employer, either by providing false details or omitting key information

when asked, which would have an effect on whether or not the candidate would be

offered the job. This includes frauds recorded as ‘successful’ and ‘unsuccessful’, as

defined below.

Successful employment application fraud | a successful application for employment

(or to provide services) with serious material falsehoods in the information provided.

This includes the presentation by the applicant of false or forged documents for the

purpose of obtaining a benefit.

Unsuccessful employment application fraud | an unsuccessful application for

employment (or to provide services) with serious material falsehoods in the

information provided. This includes the presentation by the applicant of false or

forged documents for the purpose of obtaining a benefit.

What do these results mean?

A fraudulent job application reflects upon an individual’s honesty and integrity and

may indicate a greater likelihood of that person going on to commit insider fraud.

For financial services organisations it is common to run both consumer credit and

criminal record checks, but what do the results really mean when compared to the

candidate’s original declaration?

Case in point | XYZ Bank Plc wanted to on-board candidates faster and cheaper and

so choose to only conduct criminal record checks on those who declared a previous

criminal conviction. While this did result in the overall hiring time and costs decreasing,

what were they really checking? And what about the 66% of candidates who conceal

their criminal convictions?

The Financial Conduct Authority (FCA) is clear that the honesty and integrity of a

candidate is a vital part of the on-boarding and registration process for an ‘approved

person’. Intentionally failing to declare pertinent information can be considered

“fraud by false representation” which carries a maximum sentence of 10 years

imprisonment under the Fraud Act 2006.

9

THE NEED TO SCREEN

A CIFAS staff fraud search will identify whether a candidate has been dismissed

for fraud or theft in the workplace and will therefore prevent them from moving

unchallenged on to an unsuspecting employer.

In the last five years, participating organisations have reported fraud savings of

billions of pounds through the use of the CIFAS Staff Fraud Search. Over 200,000

frauds are added to the databases each year, making it difficult to defraud

participating organisations.

For further information about the CIFAS Staff Fraud Search, see page 36.

(The CIFAS acronym derives from its former name, the Credit Industry Fraud

Avoidance Service, although its remit has since broadened beyond the credit

industry.)

10

THE NEED TO SCREEN

Higher Education Degree Datacheck (HEDD) | Student Survey

HEDD’s 2014 survey of students and graduates concluded that “it has become

common practice to change or embellish qualifications to help beat the tough jobs

market and improve chances of employment.”

The online survey of 568 students found that of those who know someone who has

embellished qualifications on a CV…

Jayne Rowley, who leads the government-backed HEDD service:

“Chancers rely on the fact that the majority of employers don’t check qualifications with

the issuing university. By raising awareness of the issues around degree fraud we hope to

encourage more businesses to dig a little deeper and not take CVs at face value.”

How HEDD defines ‘fraudulent activity’ | When someone presents a fake certificate

or alters a genuine university document - changing the name, subject, qualification,

or classification - and presents the documents as real they have committed fraud by

false representation… which can lead to prosecution resulting in prison sentences

of up to ten years.

40% 31%inflated their

gradeLied about the proportion of the

course they had completedfalsely claimed to hold

a degree

11%

11

THE NEED TO SCREEN

Career Builder | Hiring and HR Managers Survey

In a 2015 survey of U.S. hiring and human resources (HR) managers, 56% of

respondents admitted to having caught a lie on a resume.

The survey was carried out by Harris Poll on behalf of CareerBuilder between 14/

May/2015 and 3/Jun/2015 and involved 2,532 respondents.

The most common areas in which hiring and HR managers reported finding lies were:

62%

Embellished skill sets

54%39%

31% 28%

Academicdegrees

Jobtitles

Dates of employment

Embellished responsibilities

12

THE NEED TO SCREEN

First Advantage | Consumer Perceptions Survey

In August 2015, First Advantage surveyed more than 2,000 consumers on the streets

of the United States of America (USA), Asia Pacific (APAC) and the United Kingdom

(UK). Here are some of the key findings:

Our survey showed that whilst employers and employees value screening as

something which raises the credibility and trustworthiness of an organisation and

makes them feel physically safer and less concerned about theft at the work place,

candidates are still tempted to exaggerate their experience and qualifications when

applying for jobs. A combination of wanting the truth but knowing that exaggeration

is a real possibility continue to make background screening a valuable necessity for

organisations in all sectors and countries.

For the full survey results of our consumer survey, visit our blog (27/Aug/2015).

“Have you ever exaggerated on your CV/résumé?”

20%US

25%UK

24%APAC

“Would you be more or less likely to trust an organisation that screens

its staff”

“Should employers run background checks?”

“Would you be comfortable with your employer running background checks

on you?” 85% 80%69%

More likely

US UK APAC

US | 88%

UK | 85%

APAC | 58%

US | 88%

UK | 86%

APAC | 75%

Yes

Yes

13

THE NEED TO SCREEN

Discrepancy Rates

Analysis of CV checks conducted by First Advantage between October 2013 and

September 2015 shows that almost a third of all verifications found discrepancies

relating to employment, education and professional credentials (average for all

clients and industry sectors). However, in the financial services sector, discrepancy

rates are consistently lower, as illustrated below.

Financial services | 61.6%All sectors | 61.5%

CV/Résumé Comparison

Verification discrepancy rates

The proportion of checks which uncover inaccuracies

Financial services | 28.5%All sectors | 33.0%

Education & Academic Qualifications

All Verifications

Financial services | 25.5%All sectors | 29.3%

Financial services | 19.5%All sectors | 24.7%

Employment History

Financial services | 17.8%All sectors | 19.3%

Professional Credentials

14

THE NEED TO SCREEN

When comparing the overall verification discrepancy rates of key industry sectors,

First Advantage found:

We attribute the lower rate of discrepancies in the financial services industry to

greater regulation and a workforce that is increasing familiar with background

screening. While the prevalence of screening may be responsible for the lower rate

of discrepancies in this particular industry, more than a quarter of CV checks uncover

discrepancies – discrepancies that, without background screening, could have gone

undetected.

Thinking about your hiring policies and risk tolerance levels, has your business

considered all components? Are you checking all professional qualifications or just

those directly relevant to the position you are hiring for?

25.5%

FinancialServices

Industry sector comparison

Healthcare &Pharmaceuticals

Security Technology ProfessionalServices

Staffing & Recruitment

27.5%

35.5%41.3% 42.7%

46.3%

15

COMPLIANCE

Please note: the following information is correct to the best of our knowledge at the time of writing. It is provided only for informational purposes and should not be received as legal advice.

The Financial Conduct Authority (FCA) is a regulatory body unique to the UK and operates independently from the government. Its purpose is to regulate financial firms that provide services to consumers and to maintain the integrity of the UK’s financial markets.

Individuals currently applying to work in firms regulated by the FCA, known as ‘authorised firms’, do so through the Approved Persons Regime (APR). This requires authorised firms to have established criteria for due diligence and obtain regulatory approval before an individual can be employed as an approved person and perform certain ‘controlled functions’.

The FCA must be satisfied that the individual is ‘fit and proper’ to perform the controlled as pertaining to their position, which is assessed according to the following core elements:

• Honesty and integrity, • Competence, and • Finance.

The following is provided by the FCA as a guide for firms to assess a candidate’s fitness and propriety, but it is by no means definitive:

• Credit checks • Criminal record checks • Directorship checks • Evidence that the candidate possess the required skills and experience • Regulatory references (see page 22)

The Financial Conduct Authority

16

COMPLIANCE

While an approved person must comply with the ‘Statements of Principle’ – a series of binding standards of conduct issued by the FCA and Prudential Regulatory Authority (PRA) – the approved person regime (APR) does not enforce continued review or supervision of these individuals.

For further information about the FCA, visit: www.fca.org.uk

17

COMPLIANCE

Current requirements and recommendations

In alignment with current guidance, First Advantage recommends the following

package of services for all FCA regulated candidates:

Whilst this package can be customised to suit individual client requirements, the

solution outlined above will provide comprehensive due-diligence screening for FCA

applicants.

• CV / résumé comparison

• Global watch-lists and sanctions check

• Adverse media search

• CIFAS staff fraud search

Honesty and integrity

• Local consumer credit check

• International consumer credit check (based on address history)Credit checks

• Local directorship check (e.g. through Companies House in the UK)

• International directorship check (based on address history)Directorship

checks

• Local criminal record check (e.g. UK standard disclosure)

• International criminal record check (based on address history)Criminalrecords

• Education and academic qualifications

• Employment history, including regulatory references

• Professional credentials

Skills & experience

18

COMPLIANCE

Forthcoming Changes

Following the financial crisis of 2007/8, concerns were raised about the behaviour

and performance of those working in the UK financial services sector. Upon review

of the Approved Persons Regime (APR), the Parliamentary Commission on Banking

Standards (PCBS) concluded that:

• The APR acted mainly as an initial gateway rather than as a system for the

effective ongoing supervision of the most important individuals in firms;

• There was a lack of clarity of the responsibilities of individuals at a senior level;

• Institutions did not take sufficient responsibility for the fitness and propriety of

their staff at more junior levels; and

• There were gaps in the regulators’ enforcement powers.

The Bank of England has since proposed far reaching changes to Financial Conduct

Authority (FCA) and Prudential Regulation Authority (PRA) requirements for fitness

and propriety checks. Due for implementation in early 2016, these changes will have

a direct impact on employment screening for UK financial institutions.

The main elements of the proposed changes are:

• The Senior Managers Regime

• The Certification Regime

• Conduct rules

• Regulatory reference template

These proposals are intended to ensure that senior managers are held accountable

for any misconduct that falls within their area of responsibility and to hold individuals

working at all levels within banks and other relevant firms to appropriate standards

of conduct.

This means that individuals performing controlled functions will no longer be the

only employees being held to the same standards as provided by the FCA guidelines.

19

COMPLIANCE

The Senior Managers Regime

The Senior Managers Regime focuses on a narrow group of senior employees – currently approved persons performing a Significant Influence Function (SIF) – who hold key roles or have overall responsibility for whole areas in the firm or have primary/direct responsibility for briefing and reporting to the governing body or putting matters for decision-making about that function to the governing body.

Firms are being asked to assess each senior manager’s fitness and propriety by conducting appropriate screening, including but not limited to criminal record checks and regulatory references for the last six years.

The FCA is also looking for firms to ensure that they have adequate procedures in place to assess fitness and propriety not just before applying for FCA approval but also annually thereafter.

Firms will need to provide for currently approved persons to be ‘grandfathered’ into relevant roles in the new regime. Firms planning on making any new senior manager appointments or material changes to a role currently regulated under the APR will need to seek regulatory approval and submit a new application.

Enhance individual

accountability

The Senior Managers

Regime

is designedto:

Promote clear allocation of

responsibilities

Focuses on the most senior employees and those who hold key roles

Bank obligations are to assess each senior manager’s ‘fitness and propriety’

Conduct criminal record checks

Obtain regulatory references

Have procedures in place to assess fitness and propriety at least annually

20

COMPLIANCE

The Certification Regime

The Certification Regime is similar to the current process for ensuring that those

performing controlled functions have been screened to the required levels and have

had their fitness and propriety checked. The regime will also require these individual’s

certification to be renewed annually.

It is important to note that the Certification Regime will apply to all individuals

whose roles have been deemed by the regulators as capable of posing significant

risk or harm to the firm and/or its customers. These individuals should not be

confused with those carrying out Senior Manager Functions (SMFs). However, firms

will need to assess the fitness and propriety of individuals performing these key roles

and formally certify that they are fit and proper on an annual basis.

Roles deemed to be ‘significant harm functions’ are specified by the regulators but

appointments are not subject to prior approval

Staff who pose risk of

significant harm

CertificationRegime

applies to:

‘Material risk takers’

Firms will be required to certify that employees are:

Fit and proper to perform roles defined by the regulators

Screened to assess competencies

Have procedures in place to certify fitness and propriety at least annually

21

COMPLIANCE

Conduct Rules

Under the new Senior Manager Regime and Certification Regime, the principle

statements made under the Approved Person Regime (APR) will be replaced with

conduct rules which will apply to senior managers, certified persons and other

employees such as non-executive directors (NEDs).

The extension of the rules follows a gap being identified during the consultation on

the Senior Managers and Certification Regimes, whereby enforcement action for

misconduct could not be taken against NEDs. The regulators therefore decided to

include certain responsibilities, such as chairmen and chairs of key board committees,

within the Senior Managers Regime.

The new conduct rules, summarised below, will give the FCA and the PRA new

powers to take enforcement action in cases where, for example, an NED is found to

have failed to act with honesty and integrity.

First – all individuals

You must act with integrity

You must act with due skill, care and diligence

You must be open and cooperative with the FCA, the PRA and other regulators

Second – senior managers

You must take reasonable steps to ensure that the business of the firm for whichyou are responsible is controlled effectively

You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with relevant requirements and standards of the regulatory system

You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively

You must disclose appropriately any information of which the FCA or PRA would reasonable expect notice

22

COMPLIANCE

Regulatory References

As part of the fitness and propriety assessment, the FCA requires firms to obtain references from a candidate’s previous employer(s). References obtained from other authorised firms are known as ‘regulatory references’.

The FCA currently requires the following to be included in regulatory references:

• any outstanding liabilities of the candidate from commission payments• any relevant outstanding or upheld complaint against the candidate from an eligible

complainant• any information about the: o fitness and propriety section of the application for approval o the main assessment criteria of the fit and proper test.

As part of the Senior Managers Regime and the Certification Regime, the FCA and PRA will require firms to assess a candidate’s suitability for a Senior Manager Function or Certification Function. This will mean ensuring that the firm requests employment references that enable firms to make informed decisions.

Firms will be required to disclose:

• The facts that led them to conclude that the candidate breached a conduct rule, and• A description of the basis and outcome of disciplinary action taken in relation to a

breach by the candidate of any of the conduct rules.

As contained in Consultation Paper FCA CP15/31 / PRA CP36/15, the proposals regarding regulatory references to be introduced in early 2016 are as follows:

• Require firms to request regulatory references from former employers going back six years for candidates applying for Senior Manager roles and Certification Functions.

23

COMPLIANCE

• Require disclosures by relevant firms in a standard format, including the need to

• confirm where there is no relevant information to disclose.

• Require firms to update previous references given in the past six years, where they

• become aware of matters that would cause them to draft that reference differently

• if they were drafting it now.

• The event that “triggers” the need for a regulatory reference is the first time an

• individual takes on a Senior Manager role or Certification Function, even if the client

• is recruiting an individual from within their own firm – as long as the candidate has

• employment history with another employer within the last six years, the reference

• is required.

• Once the reference is on file, the firm can rely on this for subsequent moves within

• the firms, where appropriate.

• Even in situations where the firm from which the reference is sought is outside the

• financial services industry, the hiring firm should still make reasonable efforts to

• secure a reference.

• References should focus on regulatory matters only, such as issues relevant to •

fitness and propriety or confirmed misconduct, and should include, at a minimum:

o Details of any Certification or Senior Manager function role held or a

o summary of roles and responsibilities;

o Details of any other roles performed while an employee at the firm or

o firms within the same group during the last six years;

o If a firm has concluded at any time in the last six years that the candidate

o was in breach of an applicable law, a PRA Conduct rule or a Conduct

Standard they were required to observe and the facts which led to that

o conclusion;

o If a firm has concluded at any time in the last six years that the candidate

o was not fit and proper to perform a function, the facts which led to that

o conclusion; and

o Details of the basis for/outcome of any disciplinary action as a result of

the two points above.

• Outside of these minimum requirements, firms should exercise judgement in

• disclosing any additional information relevant to the hiring firm while balancing

• fairness to the employee and compliance with legal obligations.

24

COMPLIANCE

Regulatory Reference Template

The FCA and PRA have, for the first time, moved to create a standard template for

regulatory references. This will assist in achieving consistency and ensure that where

a firm has no relevant information to disclose this is clearly stated to avoid any

uncertainty.

The regulatory reference template and request for information will supplement

the existing requirement for authorised firms to provide relevant information on a

candidate’s controlled functions. Templates currently being used to obtain regulatory

references will need to be reviewed when the FCA and PRA release further guidance

on regulatory references, as further changes may be necessary.

To avoid any misrepresentation we encourage clients review the proposed template

by clicking here.

25

COMPLIANCE

Fraud and the Anti-Bribery Act

Many in the financial services industry will be familiar with the UK Bribery Act 2010.

In short, the Act makes it illegal to offer, promise, give, request, agree, receive or

accept bribes.

The UK government website offers the following advice:

You should have an anti-bribery policy if there is a risk that someone who works for you

or on your behalf might be exposed to bribery.

Your anti-bribery policy should be appropriate to the level of risk your business faces.

Your policy should include:

• your approach to reducing and controlling the risks of bribery

• rules about accepting gifts, hospitality or donations

• guidance on how to conduct your business, e.g. negotiating contracts

• rules on avoiding or stopping conflicts of interest

How does this fit into my screening policy?

Economic crime can include misappropriation of assets, accounting fraud,

cybercrime, bribery and corruption. While assets “going missing” may be a crime of

opportunity, bribery and corruption are systemic issues which erode the integrity of

your business and employees.

PricewaterhouseCoopers’s (PwC’s) Global CEO Survey showed that more than 50%

of CEOs were concerned about the effects bribery and corruption have on their

business.

26

COMPLIANCE

PwC’s Global Economic Crime Survey, released in 2014, showed that economic crime

continues in organisations across all industries and regions. The financial services and

retail/consumer sectors were amongst those found to be most at risk, with nearly

50% of respondents confirming that they had been victims of economic crime,

closely followed by communications, hospitality and government owned enterprises.

PwC also found that 56% of fraudsters are on the inside. However, the average tenure

of a typical internal fraudster shows it is not just new hires that pose a threat…

Considering the CIFAS findings on insider fraud, the value of background screening

and indeed re-screening is something which companies, particularly those in at risk

sectors like financial services, can ill afford to underestimate.

Best Practice Screening

Based on our long experience of working with banking, finance and insurance

institutions in EMEA, best practice screening will typically involve different packages

based on a candidate’s position.

As a global financial centre, many of Europe’s and indeed the world’s largest financial

services organisations are headquartered or have a presence in London, UK. As the UK

financial services sector is highly regulated, the screening recommendations provided

on the following pages are largely based on the requirements of the Financial

Conduct Authority (FCA) and the Prudential Regulation Authority (PRA).

For example, whilst verification of employment history is strongly recommended for

all financial services organisations, the six year period is a specific requirement for

regulated firms in the UK under the new Senior Manager’s Regime and Certification

Regime.

Profile of a typical internal fraudsterGender maleAge 31-40 yearsLength of service 6 or more yearsEducation level 1st degree, graduatel

27

COMPLIANCE

And with Eurozone countries preparing for ever closer banking union under the

European Central Bank, the requirements of individual member country’s regulatory

authorities are likely to become increasingly aligned. A list of financial regulatory

authorities in EMEA region is shown on page 50.

Please note: the availability of criminal record, consumer credit and directorship

checks vary significantly from country to country. See pages 43 to 45 for further

information about international criminal record checks. Please enquire for further

information about international credit and directorship checks.

28

COMPLIANCE

Education & academic qualifications

Employment history

Professional credentials

Verifications

Adverse media

Criminal record (local / international)*

Consumer credit (local / international)*

Directorship (local / international)*

Financial regulatory check (UK only)**

Global watch-lists & sanctions

Identity authentication

Record/database Checks

Low Risk Top-Up Certification Roles

Senior Managers Re-Screen

Non-key roles or roles not deemed to be ‘significant harm functions’.

Employment references only necessary if employed outside the company in last 6 years.

As defined under the new Certification Regime (CR)

As defined under the new Senior Managers Regime (SMR)

Annual package for CR and SMR roles

3 years 6 years 6 years

29

COMPLIANCE

*International criminal, consumer credit and directorship checks

To ensure fairness and relevancy, international criminal, consumer credit and

directorship checks are recommended where a candidate has lived or worked in a

country for more than, e.g., 6 months during the screening period. The screening

period and the period of living or working abroad which triggers an international

check is entirely at the client’s discretion and the ability to conduct such checks will

depend upon availability and permissibility within the relevant country/countries.

See pages 43 to 45 for more details on international criminal record checks.

**Financial regulatory check (of the FCA register)

It is important to note that the FCA register may be phased out as the Certification

Regime (CR) and Conduct Rules come into effect and the FCA moves towards self

regulation of banks and financial services organisations.(The register, would not,

however, be removed for senior manager roles, for which pre-approval will still be

required.) This change is intended to reduce the burden on the regulator, allowing

it to focus on a narrower segment of the industry. The FCA register will continue to

hold details of senior managers from March 2016 and the FCA has stated that it plans

to issue final rules on CR roles in the spring/summer of 2016.

Responses to the FCA’s consultations on this proposal have expressed concerns

about the additional responsibility it places on regulated firms. If the FCA register is

discontinued for certification roles, it is likely to put even more pressure on firms to

provide accurate and timely regulated references to one another.

Removal of the register could impact how regulated references are dealt with if

a previous employer is no longer in business. As candidates will no longer have a

unique FCA reference number, authorised firms will be reliant upon a candidate’s

name and any previously known or alternative names, which will make it even more

important to accurately verify their identity.

Different approaches to record keeping, such as the retention and maintenance of

employee records, will create challenges. For example, if there is no obligation to

maintain records for more than five years, some potential employers may find that

they are unable to obtain a full and accurate picture of the candidate.

Another potential consequence concerns FCA bans. If those with bans are not held

accountable to a financial regulator (i.e. they are not required to register with the

30

COMPLIANCE

FCA), it is possible that they could take up a position with a firm whose policies and

safeguards are less stringent.

Case in point | In 2014 Jonathan Paul Burrows, then Managing Director at Blackrock

Asset Management Investor Services Limited, was stopped at the exit gates of London

Cannon Street station and found to not have purchased a valid ticket for the entire

journey. Burrows admitted to having evaded paying the full fare on a number of

occasions despite knowing that he was breaking the law. The FCA did not consider this to

be ‘fit and proper’ behaviour for a regulated approved person and he was subsequently

banned.

If, as expected, the FCA register is discontinued, authorised firms should be prepared

to conduct additional checks to mitigate the risks to their business, such as passport

authentication, adverse media search and global watch-list and sanctions checks,

where such searches are permissible. Firms may wish to consider how they can share

pertinent information with each other in the absence of a centralised database.

31

COMPLIANCE

Financial Conduct Authority (FCA) Final Rules on Regulatory References

Following the changes earlier this year from the Financial Conduct Authority (FCA)

which began 7th March 2016, financial services organizations/Firms have had to

make several changes to the way in which they not only define regulated roles, but

also the framework for regulated references to ensure the continued assessment of

the ‘fitness and propriety’ of their employees.

The FCA and PRA have published new policy statements relating to regulatory

references under the new regimes for banks and insurers which will come into effect

7th March 2017.

At a glance the new rules require relevant firms to:

• Request and provide references that include information on the candidate’s

conduct, fitness and proprietary relevant to their function

• Seek and provide references going back six years

• Comply with the ‘Conduct Rules’

• Implement all changes by the 7th March 2017

Who does this apply to?

The rules will apply to Banks and Insurers, but will potentially be extended to other

financial services in future.

Who does this apply to?

The FCA amended rules state that firms have an obligation to provide a reference

on receipt of a request and that references must include all relevant information.

The FCA and PRA have provided a standard reference template for requesting

references, which had been discussed during the consultation period in 2015.

Along with the mandatory information prescribed by the FCA and PRA the policy

statement relating to all relevant information makes it clear that Firms will be

expected to apply judgement on a case by case basis and will be expected to disclose

all relevant information in a six year period. Firms will need to take into account

existing Handbook guidance and whether complaints or disciplinary procedures have

been upheld in order to establish whether the information they provide is relevant or

what they reasonably consider to be relevant.

32

COMPLIANCE

The FCA and PRA have also made it clear that there is no time limit for serious

misconduct and that these should always be disclosed when responding to a

reference even if they occurred outside of the six year reference period.

Who needs a reference?

Anyone going into a regulated function. This includes contingent and contractors as

well as full time employees. It may also apply to intra-group moves if the Firm does

not have a centralised way to share relevant information within a group.

Additional changes

The FCA and PRA have also stated that financial services organizations/Firms

will need to update the current employer, if that employer is a FSMA Firm, within

six years of the employee leaving if it was discovered that the candidate had been

involved in misconduct that would have materially changed the original reference

and is relevant.

This particular change has an impact on the record keeping requirements of Firms.

Firms are obliged to keep records of all disciplinary findings for six years unless

serious for which there is no time limit.

To read the Policy Statement in more detail and to see a copy of the Standard

Reference Template please review the following policy document, Strengthening

Accountability in Banking and Insurance: Regulatory References Final Rules

(https://www.fca.org.uk/sites/default/files/ps16-22.pdf)

33

COMPLIANCE

CV/résumé comparison

Verifications

CIFAS staff fraud search

CIFAS general search

China bribery record

Record/database Checks

Low Risk Top-Up Certification Roles

Senior Managers Re-Screen

Further Recommendations

Although not typically included in the screening packages of financial services

organisations, the following checks are also recommended:

For further information on individual services, see pages 33 to 39.

34

COMPLIANCE

CV/résumé comparison

FCA Requirement Our Solution Client 1 Client 2 Client 3 Client 4 Client 5 Client 6

Honesty & Integrity CV/résumé comparison

Adverse media

Global watch-listsand sanctions

CIFAS staff fraud search

Credit checks Local/internationalconsumer credit check

Directorship checks Local/internationaldirectorship check

Criminal records Local/internationalcriminal record check

Skills and experience Education/qualifications

Professional credentials

Employment (6 years)

Annual re-screening Annual re-screening

Market Comparison

The table below summarises how various financial services clients’ current screening

programmes compare with the new FCA guidelines:

In all instances, we find that our clients do not currently perform six years of

employment history (the typical period is five years) and most do not perform re-

screening

35

SERVICES SUMMARIES

Verifications

What Compares a candidate’s Curriculum Vitae (CV) / résumé with the details provided in their online application form.

Why

On discovering that they will be screened, there is the potential for candidates to enter different information in their online application form than that contained in their CV. And our analysis indicates that many candidates do exactly that, with almost two thirds (61.6%) of all CV/résumé checks for financial services organisations uncovering discrepancies (October 2013 – September 2015).

Our CV/résumé comparison service highlights any discrepancies, building a picture of a candidate’s integrity and trustworthiness.

CV / résumé comparison

What Verifies a candidate’s school, college and/or university attendance, qualifications and grades attained.

Why

Inaccurate information regarding academic qualifications is one of the most common discrepancies we uncover. In fact, more than a quarter (28.5%) of all education and academic qualification checks for financial services organisations uncover discrepancies (October 2013 – September 2015).

This type of check is particularly important for younger candidates, such as graduates, interns and trainees, for whom academic attainment is likely to be a significant factor in the recruitment decision. Not only is the likelihood of the candidate succeeding in their role often intrinsically linked to their training and academic background, advances in technology have made it increasingly easy for candidates to falsify documents or obtain non-legitimate certificates through questionable organisations or companies presenting themselves as legitimate educational institutions.

The practice of verifying only the highest achieved is mostly driven by a common denominator. For example, not every candidate will have a degree and some candidates may only hold GCSEs or O-levels, depending on when they were last in education. Specifying the type or level of qualification may mean key skills are missed. Also, the relevancy of underlying qualifications diminishes as the educational background of the candidate grows.

Education and academic qualifications

36

SERVICES SUMMARIES

What

Verifies a candidate’s employment history in any country and during any period of time (typically three, five or ten years).

With extensive language capabilities in-house and offices world-wide, we can verify employment history in almost any country/territory.

Details which we aim to verify include:

• Employer name and address• Start and end dates• Position(s) held• Salary• Reason(s) for leaving• Activities during any employment gaps• Disciplinary action (e.g. Financial Conduct Authority regulated organisations,

where applicable)

Why

Employment history and reference checks are an integral part of almost all pre and post-employment screening packages. Almost one fifth (19.5%) of all employment verifications uncover discrepancies for financial services organisations, most of which relate to dates of employment and position held (October 2013 – September 2015). Verifying a candidate’s employment history can help build-up a picture of their reliability, integrity and, most importantly, their suitability for the role and your organisation.

New FCA guidelines stipulate a six year screening period. However, the scope of employment screening should always be relevant and in-line with the role/position the candidate is entering into.

Case in point | A ten year employment screening on a school leaver aged 18 did not result in any additional benefit or mitigation for the client. However, their internal HR policies dictated that all candidates must be screened to the same level. This is an example of where candidate population and relevancy should be discussed with your screening provider.

Employment history

What

Verifies professional qualifications, licences and memberships provided by a candidate.

Details which we aim to verify include:

• Start and end dates• Graduation date• Qualification name/grade• Membership status•Membership type

Why

Possession of a professional qualification is often an essential requirement for skilled roles. Failure to adequately verify a candidate’s aptitude and credentials could lead to them performing a role for which they are unqualified or otherwise unsuitable.

Our analysis shows that nearly one fifth (17.8%) of all professional credential verifications for financial services organisations uncover discrepancies (October 2013 – September 2015).

Professional credentials

37

SERVICES SUMMARIES

Record/database checks

What This search covers a wide range of global media sources, both historical and current, and returns any instances of negative coverage.

Why

An adverse media search can be a powerful investigative tool by returning information contained in news reports, periodicals, or other main stream media outlets matching your candidate.

For example, politically exposed persons (PEPs) or individuals suspected of unlawful or immoral behaviour are generally hard to identify as PEP databases are very selective and do not always expose all adverse media coverage. A negative media search may reveal that information independently.

Candidates being recruited into senior roles may regularly appear in the media, exposing themselves and your organisation to additional scrutiny. In these cases it is important to not only ascertain their qualifications and employment history but to also ensure they will not tarnish the reputation of your organisation.

Adverse media

What This check will confirm whether a candidate has been convicted of bribery in China in the last ten years.

Why

For clients recruiting candidates who have lived or worked in China, this check will help ensure compliance relating to bribery prevention and therefore mitigate against recruitment and compliance risks.

The check will disclose details of convicted bribers where the date of conviction falls within the last ten years, as recorded in China’s national bribery record archives. The archives contain details of the following crimes:

• Offering of bribes• Units (organisations) offering bribes • Offering bribes to units (organisations)• Introducing bribes

In the two years to November 2014, 4.34 million searches were conducted on bribery cases concerning 5.79 million companies and 7.91 million individuals

China bribery record

38

SERVICES SUMMARIES

What This online search of the CIFAS Internal Fraud Database will identify any individuals dismissed for committing fraud or theft within the workplace.

Why

A CIFAS staff fraud search will prevent anyone dismissed for committing fraud or theft in the workplace from moving unchallenged to a new and unsuspecting employer.

In the last five years, participating organisations have reported fraud savings of billions of pounds through the use of this service. Over 200,000 reports are added to the database each year. The CIFAS staff fraud search can be added to any level of package and has been cited as an example of best practice by the FCA themselves.

In order to use this service there are a number of regulatory requirements and protocols that must be followed.

A CIFAS staff fraud search is only available if:• The requesting organisation is a member of CIFAS,• The candidate has a UK address within the screening period, and• The candidate gives specific consent.

For further information, visit www.cifas.org.uk.

CIFAS staff fraud search

What This check will reveal if a candidate has been the victim of fraud or identity theft, as recorded on the CIFAS database

Why

This service, performed in conjunction with an Experian consumer credit check, is valuable for employers when making a recruitment decisions as it may provide additional information regarding adverse results on a candidate’s consumer credit report.

If a candidate has been the victim of fraud or identity theft, their bank (if they are a member of CIFAS) will enter a record of the incident on the CIFAS Database.

For candidates, this service adds a layer of protection by highlighting the fact that they have been a victim of fraud or identity theft, meaning that applications for credit are scrutinised more closely in future to ensure that the applicant truly is who they say they are.

For further information, visit www.cifas.org.uk.

CIFAS general search

39

SERVICES SUMMARIES

What

This check reveals a candidate’s financial standing in order to mitigate the risk of hiring someone under financial stress.

Although a credit check, in the strictest sense of the word, is not permissible for pre-employment screening purposes in many countries (including the UK), a large amount of information is available to shed light on an individual’s financial standing, including:

• Bankruptcy• County court judgments (CCJs)• Disputed payments• Electoral searches• Individual voluntary arrangements (IVAs)

Why

Many employers consider, for example, a correlation between high personal debt and an increased likelihood of dishonesty and theft in the workplace. It is therefore particularly relevant to positions where staff have access to customer details or handle money.

Performing this check will not affect the candidate’s credit score/record in any way and the search will only be visible to the candidate.

Consumer credit

WhatA criminal record check will reveal a candidate’s criminal convictions/history. Availability of the check for employment purposes varies significantly from country to country (see page 40).

Why

For certain roles, especially those which involve working with vulnerable populations such as children or working in the healthcare sector, a criminal record check is often a legal requirement before the candidate can start work, as is the case in the UK. For others, it just makes sound recruitment sense.

All employers have a duty of care to their staff, customers, suppliers and the community. Performing a criminal record check helps prevent violent or dangerous individuals joining the workforce and ensures anyone with a relevant conviction is not recruited into a role for which they are unsuitable.

Case in point | In one of the most startling cases we’ve seen, a client in the financial services sector was surprised to receive three pages of criminal convictions for a mid-level candidate. This was particularly surprising as the candidate hadn’t disclosed a single conviction on their application.

Criminal record checks can be performed by third parties in many countries, but in some it is not permissible for employment purposes.

See page 44 for further information on international criminal record scope.

Criminal record

40

SERVICES SUMMARIES

What

Also known as a ‘conflict of interest’ check, a directorship check will establish whether a candidate is listed as a director, treasurer or holds a company secretarial position within another organisation. The search will also reveal whether the candidate appears on the list of disqualified directors.

Why

For senior management, executive level and C-suite candidates, a directorship check is an important means of establishing any potential conflicts of interest.

A comprehensive pre-employment screening form is likely to include questions which allow the candidate to declare any current or previous directorships. This search will also reveal any senior positions that candidates may wilfully or unintentionally omit from their application form.

Current FCA guidelines require a ten year directorship check.

Directorship

What

This check will reveal the following information about a candidate:

• Roles undertaken with previous Financial Conduct Authority (FCA) registered employers• Any disciplinary history and action taken by the FCA• The candidate’s status (not registered, active or inactive)• FCA reference number• Controlled functions currently performed• Current employer name• Date registered as an FCA ‘approved person’• Previous companies and ‘controlled functions’ performed with FCA registered employers

Why Employees at FCA registered firms need to be registered with the FCA in order to be an ‘approved person’ and to perform FCA ‘controlled functions’.

Financial regulatory

41

SERVICES SUMMARIES

What

This check searches a wide range of world-wide databases to identify restricted, sanctioned, prohibited, high-risk and black-listed individuals, including money-launderers, fraudsters, known terrorists, politically exposed persons (PEPs) and black-listed persons.

Why

Due to its fast turn-around time, this search is often used by financial services organisations as a compliment to a criminal records check. It encompasses multiple databases containing the sanctions/watch-lists of regulatory bodies and law enforcement agencies globally, including:

UK• Office of Foreign Assets Control (OFAC)• Her Majesty’s Treasury• Financial Conduct Authority (FCA)• Many Police Constabularies

USA• Federal Bureau of Investigation (FBI)• Securities and Exchange Commission (SEC)

Global watch-lists and sanctions

What This check verifies that the identity document(s) provided by a candidate, such as passport, driving license or identity card, are authentic.

Why

Identity authentication should always be the first check carried out on a candidate as without it any other checks may be worthless. This quick and reliable check has successfully unearthed a number of forged documents for our clients.

In certain countries, employers are legally required to verify their employees’ right to work. In the UK, failure to do so can result in fines of up to £20,000 for each illegal worker. (Between 2008/09 and 2012/13, the UK Home Office imposed 8,500 penalties totalling nearly £80m on employers of illegal workers.)

The government provides the following recommendations when carrying out a right to work verification: • Check that the photo(s) in the documents are a true likeness of the candidate• Check that the date of birth on the document seems consistent with the

employee’s appearance• If the candidate has provided a visa document, check that it covers the type of work they will be doing (including any limit on the number of hours they can work)• If different documents give different names, check that the employee can give a good reason for this (e.g. marriage or divorce)

Additional information and guidance is available at: www.gov.uk/check-job-applicant-right-to-work.

Important note: For the purpose of clarity, the responsibility for verifying a candidate’s right to work rests with the employer. An identity check compliments an employer’s right to work verification by providing reassurance that the document presented has not been forged or tampered with, but that alone does not constitute a right to work verification.

Identity authentication

42

REFERENCE

Understanding UK Criminal Record Checks

In the UK, offenders enter a ‘rehabilitation period’ following a custodial sentence, the

length of which depends upon the length of sentence and age of the offender. When

the rehabilitation period has elapsed, the conviction becomes ‘spent’. In May 2014,

the Rehabilitation of Offenders Act 1974 (ROA) was amended to increase the length of

a custodial sentence that can never become ‘spent’ from two and a half to four years.

There are three main types of criminal record disclosure available in the UK: basic,

standard and enhanced. Only certain roles are eligible for a standard or enhanced

disclosure, whereas a basic disclosure is permissible for all roles. The following table

summarises the key information available from the different types of disclosure:

What level of criminal record should I conduct?

UK Basic Disclosure

With candidate consent, a basic disclosure is permissible for any employed or

voluntary role, making it one of the most common checks we perform for clients

across all industries. Basic disclosure certificates are issued by Disclosure Scotland,

with whom we have a direct integration which allows us to submit hundreds of

requests every day.

The standard and enhanced UK criminal disclosures are now processed through the

Disclosure and Barring Service (DBS), which replaces the Criminal Records Bureau

(CRB) and Independent Safeguarding Authority (ISA). As an official registered DBS

umbrella body, First Advantage is authorised to submit and counter-sign for these

levels of criminal record disclosures in the UK.

Basic Standard Enhanced Enhanced with lists

Unspent convictions

Spent convictions

Cautions, reprimands and warnings

Local police information

Barred lists

43

REFERENCE

Basic disclosures only reveal ‘unspent’ convictions as defined by the ROA and held on the Police National Computer. Therefore, depending on whether the rehabilitation period for a given sentence has become spent, a previous conviction may or may not appear on an individual’s basic disclosure certificate.

Under the ROA, candidates are not normally required to disclose any spent convictions when applying for a job, unless the role being applied for is contained in the list of ‘exceptions’ as detailed in the ROA. The Act specifically states:

“an applicant cannot be subjected to any liability or otherwise prejudiced for failing to acknowledge or disclose a spent conviction” (ROA section 4(2) (b))

…and…

“failure to disclose the details or existence of spent convictions is not a lawful ground for dismissing or excluding any person from employment” (ROA section 4(3) (b)).

Basic disclosure certificates are usually issued within 15 days of request and are sent directly to First Advantage. We then send the certificates onto the client who must destroy the certificate within 90 days of receipt, as stipulated in the terms of the Scottish Criminal Records Office (SCRO’s) revised policy on the Storage and Handling of Disclosure information.

UK Standard Disclosure

A standard disclosure provides a full history of convictions – spent and unspent – as

well as details of any cautions, reprimands or warnings held on the Police National

Computer. Only certain ‘exempt’ roles qualify for a standard disclosure, as listed in

the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975, including:

• Any role that requires registration as a Financial Conduct Authority (FCA) ‘approved

• person’.

• Medical practitioners, barristers, accountants and other financial service roles, vets

and opticians.

• Law enforcement, such as judges, police and prison officers.

• Regulated occupations such as firearm dealers, directors of insurance companies,

nursing home staff and taxi drivers.

• Care services for vulnerable adults, health services and working with children.

• Occupations with national security implications, such as air traffic control and

certain employees of the Crown.

44

REFERENCE

UK Enhanced Disclosure

Standard disclosure requests must be submitted by a registered umbrella body, such

as First Advantage. However, unlike basic disclosure certificates, Standard disclosure

certificates are sent directly from the DBS to the candidate. Therefore, the employer

will need to ask the candidate to view a copy of the certificate.

An enhanced disclosure includes the same information as a standard disclosure

plus any additional information held by local police that is “reasonably considered

relevant to the workforce being applied for” (adult, child or ‘other’).

To be eligible for an enhanced disclosure, the role must be listed in the Rehabilitation

of Offenders Act (ROA) 1974 (Exceptions) Order 1975 and the Police Act 1997

(Criminal Records) Regulations.

As with standard disclosures, enhanced disclosure requests must be submitted by a

registered umbrella body, such as First Advantage, and the disclosure certificate will

be sent directly to the candidate.

UK Enhanced Disclosure with Barred Lists

In addition to the enhanced disclosure, either or both of the DBS ‘barred lists’

(children and adults) may also be searched. To be eligible for this search, the role

must qualify for an enhanced disclosure and involve caring for, supervising or being in

sole charge of children or adults

45

REFERENCE

Understanding International Criminal Record Checks

The availability of criminal records information varies significantly from country

to country. Although we are aware of companies offering criminal checks in all

countries, our policy is only to provide criminal record checks where it is possible for

us to do so through official channels.

We are able to perform genuine checks in many countries with candidate consent. In

certain countries only the candidate can obtain an official criminal record certificate,

which may in turn be provided to an employer (known as ‘subject access’). In

situations like this, we can assist by providing advice on how official criminal record

certificates can be obtained by the candidate.

In some instances it may be permissible to conduct a criminal record check but not

for such information to be used in making an employment decision. For example,

some results can only be considered if that information indicates that the candidate’s

working capacity, safety or reliability would be materially impaired. In other instances

making an employment decision based on a criminal history that has no material

impact or relevance to job performance may be prohibited by applicable law.

Determining whether criminal record information may be used in a hiring decision

is the responsibility of the end employer. Therefore, we strongly advise all clients to

seek professional legal advice when developing their screening programs. Having

robust hiring and screening policies in place and regularly reviewing them for their

relevancy are essential in keeping your HR practices compliant

46

REFERENCE

First Advantage International Criminal Record Scope

The table and map below show in which countries criminal record information is currently

available, either through subject access or via a third party, such as First Advantage.*

*Please note: availability currently differs depending on the platform. For example, certain countries are not available for packages ordered through CSPi but are available for packaged ordered through Enterprise Advantage. For further information, please contact your account manager.

Americas

AnguillaBahamasBarbadosBelizeBermudaBrazilCanadaCayman IslandsChileColombiaDominican RepublicGrenadaHondurasMartiniqueMexicoPanamaPeruSaint Kitts And NevisSaint LuciaSurinameUruguayUSA

APAC

AustraliaBangladeshCambodiaChinaFijiFrench PolynesiaIndiaIndonesiaKazakhstanKorea, Republic OfMalaysiaMyanmar (Burma)NepalNew ZealandPakistanPapua New GuineaPhilippinesSingaporeSri LankaThailandTongaTuvalu

Europe

AndorraAustriaBelgiumBulgariaCroatiaCyprusDenmarkFaroe IslandsFinlandFranceGermanyGreenlandIcelandIrelandItalyLithuaniaLuxembourgMaltaNetherlandsNorwayPolandPortugalRussiaSpainSwedenSwitzerlandTurkeyUkraineUnited Kingdom (inc. Channel Islands and Isle of Man)

Middle East & Africa

BahrainEgyptFrench Southern Terr.JordanKuwaitLebanonMauritiusMayotteNigeriaOmanPalestine QatarSaint HelenaSaudi ArabiaSouth AfricaUnited Arab EmiratesWestern Sahara

47

REFERENCE

First Advantage International Criminal Record Scope

48

Click here to review the new reference template.

Financial regulatory authorities

REFERENCE

Europe

Albania: Albanian Financial Supervisory Authority (FSA)

Algeria: Commission d’Organisation et de Surveillance des Opérations de Bourse (COSOB)

Andorra: Institut Nacional Andorrà de Finances (INAF)

Armenia: Central Bank of Armenia (CBA)

Austria

• Financial Market Authority (FMA - Finanzmarktaufsichtsbehörde)

• Austrian National Bank (Nationalbank )

• Austrian Takeover Commission (Übernahmekommission)

Azerbaijan

• Banking - Central Bank of the Republic of Azerbaijan

• Insurance - Ministry of Finance of the Republic of Azerbaijan

• Securities - State Committee for Securities of the Republic of Azerbaijan

Belgium

• Financial Services and Markets Authority (FSMA - Autorité des services et marchés

financiers / Authoriteit voor Financiële Diensten en Markten)

• National Bank of Belgium (NBB - Banque Nationale de Belgique/Nationale Bank van

België)

Bosnia and Herzegovina

• Republika Srpska Securities Commission for Republika Srpska

• Securities Commission of the Federation of Bosnia and Herzegovina (Komisiji za

vrijednosne papire Federacije Bosne i Hercegovina)

Bulgaria: Financial Supervision Commission (FSC)

Cyprus

• Central Bank of Cyprus

• Cyprus Securities and Exchange Commission (CYSEC)

• Cyprus Insurance Companies Control Service (ICCS)

Czech Republic: Czech National Bank

Denmark: Financial Supervisory Authority (Finanstilsynet)

Estonia

• Financial Supervision Authority (Finantsinspektsioon)

• Estonian Bank (Eesti Pank in Estonian)

FCA Mandatory Reference Request Template

49

REFERENCE

European Union

• European Central Bank (ECB)

• European Banking Authority (EBA)

• European Securities and Markets Authority (ESMA)

• European Insurance and Occupational Pensions Authority (EIOPA)

• European Systemic Risk Board (ESRB)

Finland: Financial Supervisory Authority (FSA, Finanssivalvonta)

France

• Autorité des marchés financiers (AMF)

• Registre unique des Intermediaires en Assurance, Banque et Finance (ORIAS)

• Autorité de Controle Prudentiel (ACPR)

• French Takeover Panel

Georgia: National Bank of Georgia

Germany: Federal Financial Supervisory Authority (BaFin - Bundesanstalt für

Finanzdienstleistungsaufsicht)

Greece: Hellenic Capital Market Commission

Guernsey: Guernsey Financial Services Commission

Hungary: The Central Bank of Hungary

Iceland: Financial Supervisory Authority

Ireland

• Central Bank of Ireland

• Irish Takeover Panel

Italy

• Commissione Nazionale per le Società e la Borsa (CONSOB)

• Institute for the Supervision of Insurance (ISVAP)

Jersey: Jersey Financial Services Commission

Latvia: Financial and Capital Market Commission

Liechtenstein: Financial Market Authority (FMA)

Lithuania: Bank of Lithuania

Luxembourg

• Commission de Surveillance du Secteur Financier (CSSF)

• Commissariat aux Assurances (CAA)

Malta: Malta Financial Services Authority (MFSA)

Moldova: National Commission for Financial Markets

Montenegro: Insurance Supervision Agency

Netherlands: Netherlands Authority for the Financial Markets (AFM - Autoriteit

Financiële Markten)

Norway: Financial Supervisory Authority of Norway (Finanstilsynet)

Poland: Polish Financial Supervision Authority (KNF)

Portugal

• Portuguese Securities Market Commission (CMVM)

• Portuguese Insurance Regulator (ASF)

50

REFERENCE

Republic of Macedonia

• Securities and Exchange Commission of the Republic of Macedonia (MSEC)

• National Bank of the Republic of Macedonia

Romania: Romanian Financial Supervisory Authority

Russia: Central Bank of Russia (CBR)

Serbia: Securities Commission (Serbia)

Spain

• Investment sector regulator - Spanish Securities Market Commission (Comisión

Nacional del Mercado de Valores, CNMV)

• Insurance sector regulator (life and general) - Direccion General de Seguros (DGS)

• Banking sector regulator - Banco de España (BdE)

Switzerland: Swiss Financial Market Supervisory Authority (FINMA)

Slovenia: Securities Market Agency (ATVP Agencija za Trg Vrednostnih Papirjev)

Sweden: Financial Supervisory Authority (Finansinspektionen, FI)

Turkey

• Banking Regulation and Supervision Agency of Turkey (BRSA)

• Capital Markets Board of Turkey (CMB)

Ukraine: National Securities and Stock Market Commission (NSSMC)

United Kingdom

• Bank of England (BoE)

• Prudential Regulation Authority (PRA)

• Financial Conduct Authority (FCA)

• Panel on Takeovers and Mergers

• Financial Policy Committee (FPC)

Vatican City: Financial Information Authority

Middle East

Bahrain: Central Bank of Bahrain

Oman: Capital Market Authority

Qatar: Qatar Financial Markets Authority (QFMA)

Saudi Arabia: Capital Market Authority (CMA)

United Arab Emirates

• Insurance Authority (IA)

• Securities and Commodities Authority (SCA)

• Dubai Financial Services Authority (DFSA)

51

REFERENCE

Africa

Côte d’Ivoire: Banque Centrale des Etats de l’Afrique de l’Ouest

Egypt: Egyptian Financial Supervisory Authority (EFSA)

Ghana

• Securities and Exchange Commission (SEC)

• Bank of Ghana (BOG)

Kenya: Capital Markets Authority

Mauritius

• Bank of Mauritius (BOM)

• Financial Services Commission (FSC)

Morocco: Conseil déontologique des valeurs mobilières

Nigeria: Securities and Exchange Commission

Seychelles: Central Bank of Seychelles

South Africa

• South African Reserve Bank

• National Credit Regulator

• Financial Services Board

Swaziland: Capital Markets Development Unit (Central Bank of Swaziland)

Tanzania: Capital Markets and Securities Authority

Tunisia: Conseil du marché financier

Uganda

• Capital Markets Authority (CMA)

• Insurance Regulatory Authority of Uganda

Zambia: Securities and Exchange Commission

Zimbabwe: Reserve Bank of Zimbabwe (RBZ)

52

REFERENCE

CareerBuilder (press releases): http://www.careerbuilder.co.uk/share/aboutus/pressreleases.aspx

CIFAS: www.cifas.org.uk

• 2015 Employee Fraudscape: https://www.cifas.org.uk/employee_fraudreport_junefifteen

Disclosure Scotland: www.disclosurescotland.co.uk

Financial Conduct Authority: https://fca.org.uk

•

•

•

•

•

Higher Education Degree Datacheck (HEDD): www.hedd.ac.uk

UK Government: www.gov.uk

• Anti-bribery policy: https://www.gov.uk/anti-bribery-policy

• Disclosure and Barring Service: www.gov.uk/government/organisations/disclosure-and-barring-service

• Right to work verifications: www.gov.uk/check-job-applicant-right-to-work

Please note: all content provided here is for general reference and informational purposes only. It is not intended to be and does not constitute legal advice.

Sources

Approved persons: www.the-fca.org.uk/approved-persons

Consultation Paper CP14/13: Strengthening accountability in banking: a new regulatory framework for individuals (July 2014): http://www.fca.org.uk/static/documents/consultation-

papers/cp14-13.pdf

Consultation Paper CP15/22: Strengthening accountability in banking: Final rules (July 2015): https://www.fca.org.uk/static/documents/consultation-papers/cp15-22.pdf

Consutation Paper CP15/31: Strengthening accountability in banking and insurance: regulatory references (October 2015): https://www.fca.org.uk/static/documents/consultation-

papers/cp15-31.pdf

FCA Final Notice 2014: Jonathan Paul Burrows: https://www.fca.org.uk/your-fca/documents/

final-notices/2014/jonathan-paul-burrows

FADV.com/emea

© First Advantage 2017

29th Floor 1 Canada Square Canary Wharf London E14 5AB UK

2 St John’s Street Colchester Essex CO2 7AA UK

Gate Village, Building 3, Level 1, Dubai International Financial Centre P.O. Box 127676 Dubai, UAE

Call +44 (0) 8448 24 34 44 email emea@fadv.com visit fadv.com/emea

FA031717_EMPLOYMENT_SCREENING_EMEA

As the trusted partner of over 35,000 organizations worldwide, we at First Advantage provide easy-to-understand background screening results so you can confidently make decisions about prospective employees. Not only does this safeguard your brand, but you also arrive at dramatically better background insights – insights you can rely on.

It’s time to partner with First Advantage. Now in 26 locations, 14 countries and conducting over 55 million background screens worldwide every year.

Trusted Knowledge. Exceptional People.