Acquiesce Consulting

About us

Acquiesce Consulting Limited (ACL) was established by Peter Sibthorpe to provide firms conducting investment business with professional regulatory compliance support. Through its network of contacts, all of whom have previously held senior positions within the regulatory compliance universe, ACL can provide professional compliance support in a wide range of areas. Examples of the areas covered by ACL include: money laundering prevention and the practical application of the Joint Money Laundering Steering Group’s (JMLSG’s) Guidance Notes; authorisation; product development; e-commerce; risk-based monitoring; financial promotions; senior management responsibilities (including the interlocking rules governing systems and controls, approved persons, fitness and propriety, training and competence, and the Turnbull guidelines), and; remedial work following regulatory censure.

Valority can help you to develop products, services, systems and controls that complement your business plans and satisfy your regulatory obligations. We also provide training and executive briefings, and continue to support your business on a retained basis if required.


Compliance Plan and Calendar

The Compliance Plan (the Plan) is a valuable tool. It enables you to crystallise your thoughts. The Plan spans the forthcoming twelve months and sets out the action you intend to take during that time to secure compliance with your regulator's rules. It also takes account of any changes planned by the regulator, and your own ideas to develop more efficient systems and controls.

Areas typically covered in the Plan could include your intentions to: develop databases to assist with complaint and rule breach handling, develop systems to track progress in resolving the issues that emerge during compliance monitoring activity or track and record the progress of advertising and marketing materials through your approval process. Other areas covered in the Plan might include: details of the 'compliance awareness' type training you intend to provide to the business, your compliance monitoring programme, your plans to carry out a programme of ongoing risk assessment, and the form and frequency of compliance reports you intend to provide to the Board. The Plan will indicate who will undertake the work, their qualifications and experience. The firm's Board normally ratifies the Plan.

The 'calendar', (which may form part of the Plan) is a scheduling tool. It takes account of the items that appear in the Plan, and also routine tasks, which would not normally appear in the Plan (for example, the preparation of periodic regulatory returns and management information). Naturally, the calendar is also a resource-planning tool. ACL can assist you to develop a Plan, a calendar, or both.

Reviewing the Compliance Department

An independent objective audit of a firms’ compliance department, conducted by an external regulatory compliance consultant, can pay dividends.

Areas typically covered during an audit of the firms’ compliance department include: -

Unlike an audit carried out by the firms’ own Internal Audit function, an external review conducted by an experienced regulatory compliance consultant can also consider the veracity of the guidance provided by the department to the business (for example, the ‘compliance manual’; its procedures for dealing with anti-money laundering and the financing of terrorism, and; the periodic guidance provided to the business in relation to rule changes affecting the business).

To obtain more information about this service, contact us.

Outsourcing (Third Party Administration)

You may be considering the addition of a comprehensive administration package to the services you offer to continue to compete in your existing market or add new products to your range. However, administration may not be your core business. Outsourcing administration to a third party administrator (TPA) is one solution. Your relationship with the TPA will govern the extent to which your business is accountable to its regulator for the acts and omissions of the TPA.

Typically, as part of the due diligence checks you perform you will need to prepare and issue an 'invitation to tender' (ITT), evaluate responses, create a shortlist, interview key staff, then test (and later dovetail) systems and controls. You will also need to draft a contract and a service level agreement. ACL can assist you with the selection and appointment of a TPA.


The larger financial services institutions (and some of the smaller ones) are looking to the EU as a possible future market. Some have gone further and set up dormant offices in major European cities in anticipation of setting up a Europe-wide distribution network.

You may be looking at the territories that will be most receptive to your brand, parentage and the products and services that your business can offer. You will need to consider the legal, regulatory and tax implications of penetrating this market (see ‘Regulators Around the World’). ACL can help.

Drafting and re-drafting documentation

One of the FSA's statutory objectives is to promote public awareness as a means of achieving their consumer protection objective. One of the ways they seek to do this is by improving financial literacy. It follows that the FSA will expect the financial services industry to help them mitigate the risk of creating confusion in the mind of the consumer by producing documentation that is easier to understand. ACL can assist you in the drafting of new (and the redrafting of existing) marketing materials and other documentation into 'Plain English'.

Business formation and authorisation

You may be considering setting up a new venture (for example, a funds supermarket) or evaluating the alternative structures through which you could offer a more comprehensive and attractive range of products and services within a complex group of companies (for example, by forming a life company). From managing the authorisation of a compact new venture to dealing with the issues surrounding the formation of a larger company dealing with institutional and retail investors, ACL can help.

If you are considering: the transfer of institutional or retail client's assets from one type of investment vehicle to another, new products and distribution methods, the in-specie transfer of assets, creating a track record for new funds (including those with a predecessor with similar attributes), dilution recovery, pricing, cross-selling, the formation of a marketing group, participating in or creating a 'funds supermarket', or any other issues surrounding entering a new market or the formation of a new business, contact us.

Training and competence scheme development

The FSA give firms flexibility in terms of how they attain the required standards of training and competence, but the standards firms are expected to achieve are high. Rather than being process-driven, the focus is on key outputs. The development of output-based key performance indicators is therefore crucial.

The greater application of the FSA’s rules fall upon persons dealing with private customers and the scope of the rules captures 'overseers' of certain administrative functions. If you need to review and enhance your existing training and competence arrangements, ACL can help.

ACL are also able to prepare and present 'compliance awareness' type training covering such issues as: money-laundering prevention, corporate governance, complaint and rule breach handling, investment advice, individual registration and the rules governing financial promotion.


A feature of ACL's business is to provide services to existing clients on a retained basis if required.