Unknown EMIs (6 institutions)
United Kingdom
FCA Freedom of Information data through November 2024 reveals six s166 skilled person reviews were ordered for EMIs during 2024, following a peak of 16 in 2023 and preceding figures of 5 in 2022. Section 166 of the Financial Services and Markets Act 2000 empowers the FCA to require firms to commission an independent review by a skilled person at the firm's own expense. These reviews typically examine compliance with safeguarding rules, anti-money laundering controls, governance frameworks, or risk management practices. The sharp increase in EMI s166 reviews in 2023 followed by a still-elevated level in 2024 suggests structural concerns about the EMI sector. For the BaaS ecosystem, EMI partners undergoing s166 reviews may face operational disruptions and subsequent remediation requirements.
Verified from source: FCA FOI response confirms that 6 Electronic Money Institutions (EMIs) were subject to s166 reviews in 2024 (year to date through November 2024), consistent with the candidate record's claim of six s166 skilled person reviews of EMIs in 2024.
- Elevated s166 review activity signals the FCA has systemic concerns about EMI compliance, not just isolated issues
- Fintechs relying on EMI partners should expect potential operational disruptions if their partner undergoes a skilled person review
- s166 reviews often lead to follow-on enforcement actions if serious deficiencies are identified