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Ropes & Gray LLP

FCA Releases New Rules And Draft Guidance In The Fight Against Non-Financial Misconduct

Ropes & Gray LLP on

The Financial Conduct Authority's (FCA) long-awaited new measures for tackling non-financial misconduct (NFM) in financial services are (finally) here. On 2 July 2025, the FCA published its final rules in Consultation Paper...more

Proskauer - Regulatory & Compliance

Bullying, harassment and violence set to be conduct issues under new FCA Rule

Bullying, harassment and violence set to be conduct issues under new FCA Rule - The Financial Conduct Authority (the “FCA”) recently published its Policy Statement and Consultation on non‑financial misconduct (“CP25/18”). ...more

WilmerHale

New FCA Rules on Non-Financial Misconduct

WilmerHale on

Last week, the FCA published its long-awaited policy statement containing amendments to the FCA’s Code of Conduct (“COCON”) aimed at combatting non-financial misconduct (“NFM”). NFM can amount to a breach of FCA rules in any...more

Goodwin

FCA Non-Financial Misconduct Rules: Private Fund Managers, Fintechs, and Other Non-Banks Firmly in Scope

Goodwin on

In a previous alert, “FCA D&I Standards for Large Firms Abandoned (for now), Non-financial Misconduct Rules Delayed (but Still Important),” we discussed the proposals put forward by the UK Financial Conduct Authority (FCA)...more

A&O Shearman

UK FCA plans for tackling non-financial misconduct: Next steps

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published its next steps to address non-financial misconduct within the financial services sector. With the publication of Consultation Paper CP25/18, the FCA signals its ongoing...more

BCLP

The Long-Awaited FCA Paper on Non-financial Misconduct – Was It Worth the Wait?

BCLP on

On 2 July 2025, the FCA published a further consultation paper on “tackling non-financial misconduct in financial services”. The industry has been eagerly awaiting publication of this paper, in the hope that it will address...more

Latham & Watkins LLP

FCA Sets Out Next Steps on Its Approach to Non-Financial Misconduct

Latham & Watkins LLP on

On 2 July 2025, the FCA published its long-awaited proposed next steps on addressing non-financial misconduct (NFM) in financial services. In a joint Consultation Paper and Policy Statement (CP25/18), the regulator is...more

Goodwin

FCA D&I Standards for Large Firms Abandoned (for now), Non-financial Misconduct Rules Delayed (but Still Important)

Goodwin on

In a previous alert, we discussed the proposals put forward by the UK Financial Conduct Authority (FCA) for all FCA-authorised firms to better integrate non-financial misconduct (NFM) considerations into their senior manager...more

BCLP

UK Corporate Briefing - July 2024

BCLP on

Welcome to the Corporate Briefing, where we review the latest developments in UK corporate law that you need to know about. ...more

BCLP

Former Traders Tom Hayes and Carlo Palombos LIBOR Convictions Upheld by Court of Appeal

BCLP on

R v TOM HAYES & CARLO PALOMBO [2024] EWCA 304 On 27 March 2024, the Court of Appeal (Bean & Popplewell LJJ, Bryan J) dismissed the appeals against conviction following referrals of the appeals to the Court of Appeal by the...more

A&O Shearman

D&I in FS: new rules and guidance on non-financial misconduct

A&O Shearman on

The FCA is focused on reducing non-financial misconduct to enhance the reputation of the UK financial services sector. Spurred on by positive levels of engagement with its 2021 discussion paper, the FCA’s latest consultation...more

Mayer Brown

Not so 'plain and simple': the new draft FCA rules for non-financial misconduct

Mayer Brown on

In 2018, the UK's Financial Conduct Authority ("FCA") stated publicly that "non-financial misconduct is misconduct, plain and simple", emphasising their view that the Conduct Rules applicable to most employees within...more

Latham & Watkins LLP

Recent Developments for UK PLCs - September Edition

Latham & Watkins LLP on

On 10 August 2023, the FCA published Primary Market Bulletin 45, which describes its process for developing its policy position in relation to the new ISSB standards and developing climate-related transition plan guidance for...more

WilmerHale

Responding to Allegations of Non-Financial Misconduct: Getting It Right

WilmerHale on

The UK’s Confederation of British Industry (CBI), which provides a voice for UK corporates, is facing a crisis following recent serious and well-publicised allegations of sexual misconduct. At the time of writing, multiple...more

Morgan Lewis

Preparing for Implementation of the Senior Managers and Certification Regime

Morgan Lewis on

All dual-regulated and FCA solo-regulated firms are now under the scope of the Senior Managers & Certification Regime (SMCR), with many working hard in recent months to ensure all aspects of the regime are well embedded. ...more

Akin Gump Strauss Hauer & Feld LLP

Extension of the Senior Manager and Certificate Regime Implementation Periods for Solo-Regulated Firms to March 2021

On 30 June 2020, the Financial Conduct Authority (FCA) announced proposals designed to provide breathing room to solo-regulated firms (meaning those governed solely by the FCA) in respect of the implementation of certain...more

Proskauer Rose LLP

SMCR – Top Priorities for 2020/21

Proskauer Rose LLP on

Originally published on February 24, 2020. Updated as of July 1, 2020. The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms...more

Proskauer Rose LLP

SMCR – Top Priorities for 2020

Proskauer Rose LLP on

The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms and has been in force for just over two months now. The regime applied to...more

Jones Day

Turning Tides in FCA SMCR Enforcement: Easier Targets, Non-Financial Misconduct, Changing Priorities

Jones Day on

The Situation: The Financial Conduct Authority ("FCA") is extending the Senior Managers and Certification Regime ("SMCR") to FCA solo-regulated firms on 9 December 2019 and has also released a number of statements in relation...more

Proskauer Rose LLP

Senior Managers and Certification Regime - Extension to All FCA Authorised Firms is Coming

Proskauer Rose LLP on

On 9th December 2019, the Senior Managers and Certification Regime (SMCR) will replace the current Financial Conduct Authority (FCA) Approved Person Regime for practically all FCA authorised firms, including alternative...more

A&O Shearman

UK Conduct Regulator Concludes No Changes Needed to Banking Senior Managers Regime

A&O Shearman on

The U.K. Financial Conduct Authority has published the findings of its review into the implementation of the Senior Managers and Certification Regime for the banking sector. The SM&CR came into force for banking firms in...more

Latham & Watkins LLP

FCA Warns of ‘Significant Weaknesses’ in Firms’ Implementation of the Conduct Rules

Latham & Watkins LLP on

All firms should take note of the FCA’s latest feedback on SMCR implementation. In its latest piece of feedback on firms’ implementation of the SMCR, the FCA indicated that firms must improve their implementation of the...more

A&O Shearman

UK Conduct Regulator Publishes Consultation on Regulation of Proxy Advisors under Revised Shareholder Rights Directive

A&O Shearman on

The U.K. Financial Conduct Authority has published a consultation on proposed changes to its Decision Making and Penalties Manual and Enforcement Guide to incorporate its new responsibility for regulation of proxy advisors....more

Akin Gump Strauss Hauer & Feld LLP

Senior Managers and Certification Regime

The commencement date of 9 December 2019 for the extension of the Senior Managers and Certification Regime (SMCR) to solo-regulated firms is fast approaching. The SMCR will replace the existing Financial Conduct Authority...more

A&O Shearman

Marking three years of the UK’s Senior Managers and Certification Regime

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Last month, we were joined by over 200 clients for a seminar which marked the first three years of the UK’s Senior Managers and Certification Regime (SMCR) being in force. During the first three years of the SMCR being in...more

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