In the wake of the financial crisis and a number of high-profile cases involving perceived misconduct by senior individuals in the financial sector, regulatory focus alighted on individual accountability as a means to address perceived cultural and behavioural shortcomings.
Continuing the trend, on 26 July, 2017, the UK’s Financial Conduct Authority (the “FCA”) published proposals to extend the Senior Managers & Certification Regime (the “SMCR”) to all FCA regulated firms. This briefing considers the scope of the new regime, explains how it will apply, and discusses some of the implementation challenges that firms will face.