If a firm decided that a criminal records check for a candidate for an approved person job was unnecessary and a later check revealed a criminal record, what might the consequences be?

While it is for firms to decide the appropriate checks to carry out to confirm an individual's fitness and propriety when making an application for approved person status, they should exercise their judgment cautiously. The Financial Conduct Authority would fine the firm for the failure to comply with the requirements of the approved person application and because the individual has a criminal record.