Tag Archives: Senior Managers Regime

Hong Kong to introduce new “Senior Managers Regime”

There was speculation, following the introduction of the Senior Managers Regime (SMR) in the U.K., that other regulators would follow suit and introduce similar regimes in their countries. It looks as if Hong Kong will now be the first to … Continue reading →

Cyber attack: Ignorance and inaction are no defence

For any company that relies on computers (i.e. just about any company), cyber risk is real, serious and unavoidable. Given that all company directors are legally obliged to promote the success of the companies they serve and, in doing so, … Continue reading →

Am I exposed to/protected from regulatory liability? Search me!

I took part recently in a webcast run by the British Bankers Association (BBA) entitled: “What to do When the Regulator Comes Calling” . Continue reading →

Should general counsel have “overall responsibility” for a firm’s legal function?

Sounds like there should be an obvious answer to the question in my headline? Instead in the case of U.K. financial institutions it may turn out to be a case of “be careful what you wish for”. Continue reading →

The Senior Managers Regime – Just a Matter of Doing the Right Thing?

The Senior Managers’ Regime (SMR), due to come into force in March 2016, is the U.K. financial regulators’ response to widespread concern that bank executives were not held personally responsible for the huge losses of the financial crisis. Yet as … Continue reading →

What Impact Will the Senior Managers Regime Have on Internal Investigations Involving Senior Employees?

Imagine you are a designated senior manager or perhaps simply someone subject to the Financial Conduct Authority’s new certification regime. Out of the blue, you are asked to attend a meeting with the company’s general counsel. After the initial pleasantries … Continue reading →

A New Report on the Theme of Personal Accountability Contains a Worrying Conclusion

It’s not just me who keeps returning to the theme of personal accountability for senior managers. A very recent survey and report by Thomson Reuters on personal liability of senior individuals and compliance officers contains some fascinating insights. Two findings … Continue reading →

HBOS: Why the Regulators Will Make Sure Things Go Differently Next Time

Much has been written in the last week about the long-awaited report into the reasons behind the collapse of Halifax Bank of Scotland (HBOS). This is hardly surprising given the size of the collapse and the report’s hard hitting conclusions, … Continue reading →

Personal Accountability: A Checklist for Worried Directors

Personal Accountability Checklist_645x400

I blogged recently on the recent Treasury announcement (still subject to Parliamentary approval) about the abolition of the presumption of responsibility under the senior managers regime (SMR), due to be introduced in the UK in March 2016. In the same … Continue reading →

U-Turn on Presumption of Guilt for UK Senior Managers

The UK Treasury today announced a major revision of one of the most controversial provisions in the Senior Managers Regime due to take effect on British and foreign banks operating in the United Kingdom from March 2016. Continue reading →