Interim guidance for examinations - Covid-19 impact

Supervisory examinations

In April we revised our examinations processes and timetable due to the disruption caused by COVID-19.

In line with Government developments relating to working practices, we have reviewed the extended timelines and are largely reverting to our normal working practices.

On-site examinations

For the remainder of 2020 we will continue to conduct the ‘on-site’ element of our examinations remotely.

We will do this through desk-based reviews of the material we ask you to submit to us. If we have any questions, we will direct them to a designated member of your team, who can co-ordinate your responses via e-mail or myJFSC.

We will continue to conduct examination meetings and interview key members of your team, but we will hold these by telephone or video conference, as appropriate. At least two members of JFSC staff will attend all virtual interviews.

We will review this position before year end and provide an update with regards to planned activity for 2021.

Financial Crime Examination Unit examinations

Stage	Timeline
Examination notification	8 weeks prior to examination
Submission of requested information	4 weeks prior to examination
Remote on-site activity	10 working days (if required)
Debrief meeting	27 working days post examination
Draft report issued post debrief meeting	10 working days
Factual accuracy response to draft report	20 working days
Final report issued	As soon as practicable
Submission of action plan	20 working days

Risk based examinations

Stage	Current Timeline
Examination notification	6-8 weeks prior to examination
Submission of requested information	Generally 4 weeks prior to examination
Remote on-site activity	10 working days (if required)
Debrief meeting	27 working days post examination
Draft report issued post debrief meeting	10 working days
Factual accuracy response to draft report	20 working days
Final report issued	As soon as possible
Submission of action plan	20 working days

Thematic Examinations

Stage	Current Timeline
Examination notification	6 - 8 weeks
Submission of requested information	4 weeks minimum (no change)
Remote on-site activity	2-5 working days (depending on subject matter)
Debrief meeting	N/A
Draft report issued	As advised by JFSC
Factual accuracy response	20 working days
Final report issued	As soon as possible
Submission of action plan	20 working days

For thematic examinations, we will publish the draft report on an agreed date for all businesses that we examine.

Before the examination

Notifying you about an upcoming examination

Our supervisors will contact your business to let you know the type of supervisory examination we wish to undertake and to agree a suitable date for it to take place.

Our Examinations Unit will then follow up in writing with details of the examination and the team that will be conducting it.

Typically, the team carrying out your examination will comprise your supervisor and two examiners, depending on the type of examination and the size of your business.

Request for information

Before we undertake our examination, we will request information from your business so that we can carry out a desk-based review. Our lead examiner will email your designated primary contact to request this information, providing exact details of what we require and by when.

If you have any concerns about the information you need to collate and the deadline for providing it, you should raise this at your preliminary meeting with our examination team and we will work with you to agree a solution.

You can find details of the timelines for providing us with this requested information in the tables above.

Submitting your information

You will need to upload all the information we request from you to myJFSC, using your specific examination reference number and our standard naming conventions.

We will send you guidance about how to upload your information to the portal.

We may need to disclose the information you submit to us to third parties in order to fulfil our statutory functions effectively. This includes, but is not limited to, sharing personal data, described in our Privacy Notice. If you want to know more about how we may share data, please speak to your usual JFSC contact or our Data Protection Officer.

Requests for additional documents

In order to complete our examination, we may request further information from you at any time.

We will try to request information as soon as possible so that you can upload the documents to myJFSC. We will give you exact details of the information we require and advise you of the naming convention to use when uploading.

Security of your documents

We have developed the portal with security measures to ensure the confidentiality and integrity of your data. These security measures have been reviewed and tested by external providers who have significant experience of dealing with the security of highly sensitive information.

Preliminary meeting

After you have received our request for information, we will hold a preliminary meeting with you via video conference to explain the examination in more detail and to answer any questions you may have about the process. With your primary contact, we will agree how and when this meeting will take place.

During this preliminary meeting, we will discuss how we will hold our future meetings.

Our lead examiner will also walk you through our information request to make sure you understand what information we need from you.

At this meeting, you will have the opportunity to raise any queries you may have about the examination.

Remote on-site activity

Duration

In the table above, we have indicated the timelines for completing the remote on-site activity. These timelines are a guide, as some examinations may need to be shorter or longer, depending on the type of examination and the size and complexity of your business.

We will let you know during your examination if we need more or less time.

Process

Before we start our remote on-site activity, our lead examiner will provide you with a schedule of meetings that we will be conducting with key personnel and members of your Board / senior management, as well as interviews with your employees. We will give you this schedule as soon as possible so you can make arrangements or we can accommodate any changes.

We will review files remotely and will email you a list of the ones we want to examine as soon as possible, including client files. We will send you details of the information we require from your client files and you will need to submit these to us through myJFSC.

At the start of our remote on-site activity, we will have a meeting with you via video conference. This will be to give you an overview of any areas that we need clarification on following our initial desk-based review of your documents.

Each day, at a mutually agreed time, we will hold a brief close-out meeting with you to update you on our progress. We will have a note-taker from our examinations team present at these meetings.

On the last day, we will aim to hold a soft close-out meeting with you to discuss our thoughts. This is to ensure there are ‘no surprises’ when you receive our draft report.

Interviewing your staff

Before we start our remote on-site activity, we will give you a list of employees who we will need to interview. We will most likely speak with your Key Person/s and interview some or all of your Board / senior management team. Our examiners may also want to speak with other members of your staff, but we will always let you know the names of these employees before any meetings take place.

Any member of your staff who is being interviewed can request to have a senior colleague present. We do ask that the senior colleague allows the interviewee to answer our questions. We will also ask the senior colleague to leave before the end of the interview.

JFSC meeting notes

We will not share or provide copies of the meeting notes taken by our examinations team. Any members of your staff who we interview can make their own notes during meetings.

Our examination findings

Our team will discuss any findings they identify with your key staff at the daily meetings. This gives you the opportunity to consider any potential issues and provide any additional information, data or documents to the examinations team to review before we issue our draft report.

Reporting

You can find details of our reporting timelines in the tables above.