When recruiting someone who will not be an approved person, does the same fit and proper test as for approved persons apply?
Not directly. However, responsibility for having a proper recruitment policy lies with a firm and its senior management, which would normally mean that the same fitness and propriety tests would apply. The judgment as to whether or not someone is fit and proper would be for the firm alone, and not the firm and the Financial Conduct Authority, as is the case for an approved person. The firm has more freedom in deciding how far it requires, for example, background checks or reference checks, which may or may not be appropriate for a particular job.