Due diligence checklist, United Kingdom

FCA SYSC 8: what to ask a vendor

FCA Handbook, SYSC 8 Outsourcing. FCA. Outsourcing a critical function must not weaken internal control or the FCA's oversight.

A starting point, not legal advice. The regulator's own page: FCA.

What it is

Outsourcing a critical function must not weaken internal control or the FCA's oversight.

Who it applies to

Applies to every financial institution in the United Kingdom.

What to ask a vendor, and the evidence to request

#Ask the vendor forEvidence to request
1Cooperation with the FCA, including access to data and premisesThe contract clause giving the institution and its regulator access, audit and information rights, and the vendor's process for an audit request.
2No impairment of the institution's control over the outsourced functionA written statement from the vendor, with the policy, specification or sample that supports it.

In every case

  • A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
  • Which named customers the vendor already serves under this regime, as references you may call.

This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.

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