Blogs

What lies ahead for Financial Services?

Stress-Tested for Reality: Beyond Paper Plans

In a recent blog, the UK’s FCA strikes a frank and open tone: operational resilience is not a box-ticking exercise. This is a message that has been sent before, and we hear it again in this blog issued on 15th April 2025. Operational resilience is business critical....

Is SM&CR working?

The SM&CR review was announced as part of the Edinburgh reforms towards the end of 2022, with HM Treasury indicating that “ some stakeholders have raised concerns about their experiences of specific aspects of the regime .” Consequently, the government is assessing...

Why Managing Conflicts should still be on your agenda!

Conflicts of interest is a subject matter that should be relatively easy to understand and as such, straightforward when it comes to compliance. Why then do we hear of senior managers who have failed to declare a potential conflict or to recuse themselves from related...

SM&CR: an update for FMIs

UK Government issued a consultation paper last year setting out its proposals to replicate the Senior Managers & Certification Regime (SM&CR) for Financial Market Infrastructures (FMIs), who are not authorised firms. Here we look at the outcome of that consultation....

Do amended CPD requirements offer greater flexibility?

One of the fundamental obligations applicable to all regulated firms is the need to implement appropriate processes to manage risks. One such risk is that of providing unsuitable advice to consumers. This area has been a regulatory hot topic for some time. Remember the...

Assess & Prove Competence

The Senior Managers & Certification Regime (SM&CR) was first introduced in 2016 for banks and then phased in until it was finally extended to include the remaining regulated firms at the end of 2019. SM&CR aims to encourage greater accountability within firms whilst...

Has SM&CR made a difference?

The Senior Managers & Certification Regime (SM&CR) for insurers took effect in December 2018. As part of the Solvency II regime, insurers were already subject to the Senior Insurance Managers Regime (SIMR) introduced in 2016. Despite that, there were some new...

Accountability in Financial Services

Since the financial crisis of 2008 regulators worldwide have been introducing reforms to improve individual accountability within firms. Regulators were criticised for their lack of action and not preventing the crisis. Further criticism was aimed at firms’ failings...

FMIs, Get set for SM&CR

HM Treasury issued a consultation earlier in July. The proposals signal HMT’s intention to extend the Senior Managers & Certification Regime (SM&CR) to include Financial Market Infrastructures (FMIs). Interested parties should submit their responses by 22 October 2021....

HR & Compliance – Bridging the Gap in SMCR

Since the introduction of the Senior Managers and Certification Regime (SM&CR), it has been interesting to see how and where firms have allocated most of their resources to comply with the new rules. Implementation tends to follow one of two strategic approaches:...

SMCR Responsibilities – Documenting Risks and Controls

In light of the turbulence caused by the Covid-19 pandemic, SMCR may have been pushed down the priority list for most firms for now. The disruption has however given rise to a number of practical and compliance challenges which have a direct and imminent impact on...