If you've been referred to Purely Pensions by your overseas financial adviser, you're probably doing your homework. That's exactly the right instinct. This guide explains who Purely Pensions are, why they exist, what the advice process looks like, and, crucially, what role your overseas adviser plays in all of this and whether that adviser is really the right one for you.
Why You've Been Referred to a UK Pension Transfer Specialist
You live outside the UK. You have a defined benefit (DB) pension, also known as a final salary scheme, from a former employer. Your financial adviser has identified it as something worth reviewing and has now told you that, before anything can happen, you need to speak to a UK-based pension transfer specialist firm called Purely Pensions.
This probably feels like an extra layer of complexity. In fact, it's a legal requirement, and understanding why it exists will help you make sense of everything that follows.
Since the introduction of pension freedoms in 2015, the law has required that a suitably authorised FCA-regulated adviser must advise on any transfer of safeguarded benefits worth over £30,000 before the transfer can proceed. This applies wherever in the world you live. Your overseas adviser, however qualified they are in their own jurisdiction, almost certainly does not hold the FCA permission required to give this advice. Purely Pensions does.
The FCA explicitly recognises that non-UK residents considering a pension transfer are likely to need advice from two separate firms: an overseas adviser for investment and specific pension provider advice, and a UK adviser for advice on the actual proposed transfer of safeguarded benefits. This two-adviser structure is the correct and recognised framework for expats in your position, and this is why the FCA formerly brought out a guidance paper, elaborating and formalising the two-adviser (sometimes known as “dual-adviser”) model.
So the referral to Purely Pensions is not unusual. It's how the process is supposed to work.
Who Are Purely Pensions (Purely Financial)?
Purely Pensions is the trading name used by Purely Financial for their defined benefit pension transfer specialist service. They are FCA-authorised and hold the specific regulatory permission required to advise on DB pension transfers, a permission that requires their advisers to hold the AF7 qualification (Level 6 Award in Regulated Pension Transfer Advice) alongside a full Level 4 Diploma in Financial Planning.
Their model is built around what is sometimes called the overseas advice model. They work with international financial advisers around the world, firms advising expats in the US, Europe, the Middle East, and elsewhere, by stepping in as the UK-regulated specialist piece when those firms' clients have a DB pension to review.
Their job is narrow but critical: to independently assess whether transferring your DB pension is in your best interests, and to produce a formal suitability report that either recommends the transfer or advises you to retain your benefits. That report is required by your pension scheme trustees before they can process any transfer.
The fact that they focus specifically on this, rather than trying to be a full-service wealth manager, is actually a feature, not a limitation. DB transfer advice is highly specialised, carries significant regulatory scrutiny, and requires advisers with specific qualifications and professional indemnity insurance. Purely Pensions has built its firm around doing this one thing properly.
Is Purely Pensions a Good Choice?
For the DB transfer advice itself, the regulated UK piece, Purely Pensions, is a credible, FCA-authorised specialist operating in a legitimate and well-understood part of the market. If you can verify their FCA registration and confirm their advisers hold the requisite qualifications, you have no particular reason to be concerned about the UK advice process they will provide.
Here are the questions worth asking before you proceed with any Pension Transfer Specialist, including Purely Pensions:
Are they FCA-authorised with the correct permissions? Check the FCA Register at register.fca.org.uk. You are looking for the firm to hold the permission “Advising on Pension Transfers and Pension Opt-Outs.” Any firm without this specific permission cannot legally provide DB transfer advice. Purely Pensions are.
Will they engage with you directly? A properly run Pension Transfer Specialist insists on conducting its own fact-find, its own risk assessment, and its own analysis, independently of what your overseas adviser has told them. Be cautious of any process where the UK firm communicates almost entirely through your overseas adviser rather than with you personally. Whilst Purely Pensions will work with the overseas adviser to help obtain the requisite information about you and your scheme, once the actual advice process starts, it is all between you and your pension transfer specialist. It is only when the advice is provided, and you have indicated what you want to do next, that the overseas adviser is then brought back into the fold.
Will they provide full advice, not abridged? You should receive a comprehensive suitability report covering the value of your guaranteed benefits, the proposed receiving scheme, the charges involved, and a clear recommendation either way. Abridged advice is not sufficient for a DB transfer of this nature.
Are their charges transparent? You should know exactly what you are paying Purely Pensions, and how that cost is being met, before the advice process begins. Be aware that where the cost is being absorbed by your overseas adviser or built into a product charge elsewhere, that is worth understanding clearly. Due to the extent of our work with Purely Pensions, Cameron James has access to significantly reduced rates with Purely Pensions, which may be lower than what you will pay with other advisers, including the one who referred you to Purely Pensions.
Will they advise against transferring if that's the right answer? The FCA's starting position is that a DB transfer will be unsuitable for most people. A reputable specialist will tell you to keep your pension if the numbers and your circumstances warrant it, regardless of what your overseas adviser would prefer, or may be pushing you towards in the background.
If Purely Pensions is ticking these boxes, they are doing their job.
The Part of This Process That Purely Pensions Cannot Cover
Here is the most important thing to understand about the two-adviser model: Purely Pensions' advice covers one question. Should you transfer your DB pension or not?
That is a significant question. But it is not the only question you should be asking.
Your overseas adviser is the one deciding where your pension money goes once it leaves your DB scheme. They are choosing the SIPP provider, the investment platform, the funds, the charging structure (which is also reviewed by Purely Pensions as part of the Transfer comparison), and the ongoing advice relationship. Purely Pensions is not advising on any of that. Their mandate is the transfer itself.
Some questions fall outside Purely Pensions' scope but are absolutely critical to your decision:
- Is the proposed SIPP provider and investment strategy appropriate for a non-UK resident, and specifically for someone resident where you are?
- How will your pension lump sum and income be treated by your local tax authority?
- What are the local financial reporting requirements
- How does your UK pension fit in with your wider retirement plan and accounts?
- Is your overseas adviser actually authorised to advise you in your country of residence? Are they SEC-registered if they are advising US persons, for example?
These are questions your overseas adviser should be able to answer in detail. If they cannot, or if they are vague, dismissive, or unable to demonstrate proper dual-jurisdiction knowledge, that is a more significant problem than anything relating to Purely Pensions.
The Real Due Diligence Question: Is Your Overseas Adviser the Right Fit?
When you are doing your homework on this process, it is natural to focus on Purely Pensions. They are the unknown name that has just entered the picture. But they are the regulated, transparent part of the model. The part worth scrutinising more carefully is the overseas adviser who introduced you to them.
The FCA has been clear that it is concerned about overseas firms targeting the UK pension benefits of DB scheme members living overseas. The concern is not that the two-adviser model is problematic; it is entirely legitimate. The concern is that some overseas advisers use it to dress up a pre-determined transfer recommendation in a layer of apparent regulatory compliance.
The warning signs include:
You were told a transfer was the right move before Purely Pensions had assessed anything. The overseas adviser should be presenting a DB transfer as a possibility worth exploring, not a conclusion already reached. The DB transfer advice belongs to Purely Pensions, not to the firm that referred you.
You were approached cold. Reputable international financial advisers build client relationships over time. If you were cold-called or contacted out of the blue by a firm focused on your UK pension, apply particular scrutiny.
Your adviser cannot clearly explain what will happen to your money after the transfer. The SIPP provider, the investment strategy, the platform charges, and the ongoing advice fees: you should receive a clear, written disclosure of all of these before you proceed.
Your adviser is not authorised in your country of residence. If you are a US person, your financial adviser should be SEC-registered or work through a properly registered firm. FCA authorisation does not give an adviser the right to advise most non-UK resident persons on investment matters. This is a regulatory red line.
The proposed investment strategy involves unfamiliar, offshore, or commission-generating products. Charges on overseas investment products can be complex and, in some cases, structured in ways that significantly erode long-term returns. If you are being steered toward high-charging offshore bonds or packaged investment products, ask hard questions about the total cost and who benefits from the recommendation.
None of this necessarily applies to the firm that referred you. But if you are doing due diligence on Purely Pensions, you should be doing equally rigorous due diligence on the adviser who put you in touch with them.
Where Cameron James Fits
Cameron James is a UK & UK Expat financial planning firm, with advisers who are all FCA-authorised in the UK, and EEA regulated in Cyprus, with many who are also SEC-registered under Cameron James USA.
We work with Purely Pensions in the two-adviser model in the way it is designed to operate. Cameron James acts as the overseas adviser handling the holistic cross-border plan, while Purely Pensions provides the independent UK specialist DB transfer advice. All defined benefit pension transfer enquiries with Cameron James are completed by an independent, third-party FCA-regulated Pension Transfer Specialist.
If you are currently working with another international adviser who has referred you to Purely Pensions, and you have questions about whether that adviser is the right fit, or whether the overall strategy being proposed is sound for a US person, Cameron James can provide a second opinion before you commit to anything.
That second opinion would cover:
- Whether the proposed SIPP and investment strategy are appropriate for your specific situation, especially your tax residency
- Your tax reporting obligations
- How your UK pension integrates with your other retirement accounts and overall retirement plan
- Whether the total costs of the proposed arrangement, across both the SIPP and the overseas advice relationship, are reasonable and transparent
A DB pension transfer is irreversible. Getting a second perspective on the full picture costs very little compared to the risk of getting it wrong.
If the adviser you're currently working with is well-qualified, properly authorised, and genuinely acting in your interests, a second opinion will simply confirm that and give you confidence to proceed. If there are gaps in their authorisation, their cross-border knowledge, or the suitability of what they are proposing, it is far better to discover that now.
Summary: What You Should Take Away From This
Purely Pensions is a legitimate, FCA-authorised Pension Transfer Specialist operating within the recognised overseas advice model for UK expats with DB pensions. If your overseas adviser has referred you to them, you are at the right stage of the process, and the referral itself is not a cause for concern.
If you have any concerns about your advice process or the Financial Adviser who referred you to Purely Pensions, then please contact us, and we will put you in touch with one of our great advisers to discuss things further with you.
This article is for informational purposes only and does not constitute personalised financial or tax advice. Defined benefit pension transfers involve significant risks, including the permanent loss of guaranteed income. Always seek regulated financial advice tailored to your personal circumstances before making any decision.