Tag Archives: Senior Managers Regime

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 →

Whistleblowers: You Know they Make Sense if You’re a Regulator!

Whistleblowers

The FCA published last week new rules on whistleblowing. The key requirements of the new rules are to: appoint a senior manager as their whistleblowers’ champion put in place internal whistleblowing arrangements able to handle all types of disclosure from … Continue reading →

The Chief Risk Officer: When a Triangle Becomes a Square

4 executives

The traditional shape for the apex of a pyramid is a triangle, right? Translate that into an organogram for any large organisation and you can be sure that the three corners will be occupied respectively by the Chief Executive, the … Continue reading →

The Age of Irresponsibility Is Over – You Heard It Here First

Bank of England

It’s not often that a single speech provides enough material for a blog piece, but when that speech is by the Governor of the Bank of England and expressly calls for a significant expansion of the regulatory regime as well … Continue reading →

Challenging the “Murder on the Orient Express Defence”

The latest slew of fines against banks (almost US $6 billion) in wake of the FOREX scandal has attracted predictable headlines from the press along the lines of “How can it be that so few individuals have been held to … Continue reading →

Regulatory Review of 2014

year-in-review

As we close the book on 2014, we look back at the Financial Conduct Authority’s progress and select three important stories of 2014. Continue reading →