The problem with most firms, whether they be IFAs, Stockbrokers, Payment Services or whatever sector, is that the Compliance Officer is treated unfairly, if they are running the compliance function as a component of their job. Whether they are advising, trading or operate the financial side of the business, unlike 10 or even 5 years […]
Compliance is an ambivalent function. On the one hand you are viewed as the regulators’ ally inside the investment firm; overseeing the implementation of their regulation. Meanwhile, you are paid by the investment company and a component of their culture and hierarchy. You might say ‘front office’ (traders making the money) considers compliance the way […]
SMCR and the inbuilt code of conduct rules are one of the strictest accountability codes of any industry with executives vulnerable to penalties including fines, jail and career implications.
This post summarises the steps which core and limited scope and enhanced firms are likely to have to take in order to adhere to the regime. To promote internal discussion and planning around these changes, we summarise a few of the steps which will be required relative to SMCR. Although only senior managers have to […]
The Senior Managers & Certification Regime (SMCR) and Conduct Rules mark a new era for the UK’s beleaguered financial services industry. The new regime is one of the strictest individual accountability guidelines across all industries, leaving executives vulnerable to penalties, including jail, for failings beneath their oversight.
This is not only a “Compliance” thing, it is most certainly an area in which not only the board, executive committee and individual directors must definitely appreciate what they are liable for, but other teams in the business likewise. The HR function must play a principal role in dealing with the processes that underpin long-term compliance.
The philosophy of “conduct risk” has bubbled to the top of firms’ and regulators’ agendas in the last few years. In the UK, the FCA presumes conduct risk management to become implanted into firms’ risk management frameworks, maintained by suitable management information (MI). Developing on ongoing regulatory and supervisory expectancies and our years of experience […]
The philosophy of “conduct risk” has risen to the top of firms’ and regulators’ agendas lately. In the UK, the FCA presumes conduct risk management as being lodged into firms’ risk management frameworks, sustained by relevant management information (MI). Building on latest regulatory and supervisory expectations and our expertise of what works well in practice […]
The philosophy of “conduct risk” has risen to the top of firms’ and regulators’ agendas lately. In the UK, the FCA presumes conduct risk management to be embedded into firms’ risk management frameworks, sustained by suitable management information (MI). Building on latest regulatory and supervisory requirements and our prior experience of what works well in […]
In March 2018, the FCA released its consultation paper (CP18/6) on its proposed approach to the application of the European Banking Authority’s (EBAs) final guidelines on security measures for operational and security risks of payments services under PSD2. The Latest Approach document, Version 2, was released 19th December 2018 https://www.fca.org.uk/publication/finalised-guidance/fca-approach-payment-services-electronic-money-2017.pdf. Generally, the documents do not […]