Case Study: Regulated Financial Services Training

At Unlock Staff Potential all our trainers who provide regulated financial services training are qualified to the FCA standards.


We were recently called upon to deliver face to face Regulated Financial Services Training to a UK Bank to cover the topics of Know Your Customer (KYC), Client Vulnerability and Absent Customers. 

What was the challenge?

The UK Bank had previously been challenged upon its procedure after arranging a foreign currency mortgage for joint borrowers. One of the borrowers was a foreign currency trader by occupation and due to their expertise, dealt with all the transactional paperwork and followed the bank’s advisory procedures in relation to the currency mortgage application. 

Although the bank obtained the required paperwork in respect of an absent customer, the bank was unsuccessful in calling up the debt when the customers failed to meet the monthly repayments due to the fact that the bank could not demonstrate sufficient protection had been provided for the absent party, who was joint and severely liable for the debt. 

How we provided a solution

A full review of procedures was undertaken by the bank’s compliance department and we retrained the staff on KYC, Client Vulnerability and Absent Customers. We also trained the staff on soft communication skills to deal with customer situations where one party has professional knowledge and the other party does not. 

KYC Verification Process – 3 Steps to Know Your Customer Compliance

Know Your Customer procedures are a critical function to assess customer risk and a legal requirement to comply with Anti-Money Laundering (AML) laws. Effective KYC involves knowing a customer’s identity, their financial activities and the risk they pose. 

The entire identity verification procedure does encompass a lot; however, the most important ones are: 

  • Customer Identification Programme (CIP)
  • Customer due diligence
  • Ongoing monitoring

Client Vulnerability

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. 

To achieve good outcomes for vulnerable customers, firms should take action to: 

  • Understand the needs of their clientele
  • Ensure their staff have the correct skills and capability to recognise and respond to the needs of vulnerable customers
  • Monitor, and assess staff are meeting and responding to the needs of customers with characteristics of vulnerability, and make improvements where this is not the case

Absent Customers

All firms must be able to show consistently that fair treatment of customers is at the heart of their business model’.

This situation arises commonly where there are two parties taking advice but only one party is present at the meeting, either face to face or via the telephone. The risk to the absent customer is that they are not fully aware of all aspects of the advice provided or the party that was present at the meeting does not fully explain to them, the advice received. 

Financial Services Companies still have a duty of care to that absent party and need to hold evidence that the absent party is fully aware of all aspects of the advice received. Often signed paperwork is insufficient, there is also a requirement to hold a verbal conversation with the absent party prior to documentation being signed. 


On the day we also covered the following communication topics as they dovetailed well with the learning material. 

Non-Verbal Signs 

Body Language: A famous study by Professor Albert Mehrabian told us that non-verbal signals play a large part in any communication between people; the 7%-38%-55% communication rule: 

  • 7% words used
  • 38% way we say (intonation)
  • 55% body language

Individuals find it easier to control what they say than to conceal their gestures. Gestures expose clues to your thoughts. To conceal unwanted displays of your thoughts, be mindful of the motions you make. 

Listening Skills: Active listening is a technique of careful listening and observation of non-verbal cues. It is a skill that can be acquired and developed with practice.

Verbal Signs 

Effective speaking involves the words you choose and how you say them. Verbal communication skills work when you: 

  • Think before you speak
  • Are clear and concise
  • Speak with confidence
  • Vary your vocal tone
  • Are an active listener
  • Are aware of non-verbal communication cues
  • Think about the perspective of your audience

Written Communication 

Writing is about more than just grammar and spelling. These are important skills but it is also about style, tone, and punctuation. 

Regulated Financial Services Training 

Here at Unlock Staff Potential, we can help you just like we help our clients. We have experience in delivering new legislation and upskilling knowledge on existing legal requirements with the emphasis on delivering outstanding outcomes for your clients. Under Regulated Financial Services Training we are authorised to train your staff in the following areas: 

  • Mortgages
  • Pensions
  • Life Insurance
  • Investment
  • Together with Know Your Customer (KYC) and specific areas such as Client Vulnerability

Get in touch with us today to find out more about how we can help you.