If you work in financial services you will have a responsibility towards your clients and customers, so there is a strong likelihood that you will need a CRB check.
A degree in finance and any accountancy qualifications won’t count for much without the vital ingredient – clearance from the Disclosure and Barring Service (DBS), commonly known as a CRB check.
Accountants must undergo a standard CRB because you have a position of high responsibility in dealing with the finances of others.
To be suitable for your role in this field it is law (under the Rehabilitation of Offenders Act 1974) that you have CRB check clearance. This is understandable given the fact you are responsible for disclosing financial information on companies or even individuals.
Standard CRB check
This, with your consent, will be applied for by a potential employer or, if you are self-employed, by a screening service or organisation that is registered with the DBS. This check flags up all convictions, spent or unspent.
It depends on the type of conviction, whether you will be deemed suitable for the role or not. Offences that are generally unacceptable are those pertaining to financial misconduct or fraud.
Spent convictions filter
A spent conviction, depending on the nature of your crime, it can be filtered through the Disclosure and Barring Service (DBS), which has replaced the Criminal Records Bureau (CRB) in conducting checks. If you were convicted, for example, of common assault when you were young, this conviction won’t be show up on your DBS check forever. A conviction such as common assault, will be filtered from the checking process after 11 years and if you were a minor it is five and a half years.
Roles requiring standard DBS clearance
- Chartered Accountants: all certified accountants must have DBS clearance because they will be working with other people’s money and often these clients could be deemed as vulnerable.
- Financial Services Positions: this includes any role which requires approval from the Financial Conduct Authority (FCA) due to involving a ‘controlled function’. This would include positions like overseeing a regulated firm’s systems and/or controls, serving as director of a regulated firm and all other roles that require the employee to comply with the FCA’s rules.
The ”fit and proper” test
If you are a senior manager, a non-executive director or a chartered account your role could fall under the auspices of the FAC’s SM&RC (Senior Managers and Certification Regime). The SM&RC is there to ensure standards across the finance industry. Part of this regulation is its “fit and proper test”.
A fit and proper test” looks at:
- honesty, integrity and reputation
- competence and capability
- financial soundness
To back up this test, the following is carried out:
- Criminal record checks – if you are applying for a senior management role, you must declare your criminal history, if you have one. This is where you will be required to have a standard DBS check.
- References – this must be from all employers in the past six years. These references will contain any disciplinary actions, giving your potential employer an idea how you will conduct yourself in your new role.
Prior to December last year the FCA had the Approved Persons Regime (APR) in place to keep standards consistent in the industry. The FCA then decided to include senior managers in all financial sectors. It had been used in banking prior to December 2019 and proved to be an effective tool.
Dealing with other people’s money matters requires someone with an unblemished record when it comes to honesty and integrity, which is why a CRB check is so vital.
