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Senior Managers United Kingdom

A&O Shearman

UK SMCR overhaul: understanding the FCA, PRA and HM Treasury's proposals for reform

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Since its inception in 2016, the Senior Managers and Certification Regime (SMCR) has served as a cornerstone of the UK’s financial services regulatory landscape, designed to enhance individual accountability and raise...more

Mayer Brown

FAQs on Proposed Reforms to the UK Senior Managers and Certification Regime

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The Senior Managers & Certification Regime ("SM&CR") has been a cornerstone of the UK’s individual accountability regulatory framework for banks, insurers and other regulated firms since its introduction in the wake of the...more

DLA Piper

Corporate Criminal Responsibility Set for Reform in the UK: The Crime and Policing Bill

DLA Piper on

Corporate criminal responsibility in the UK is poised for further reform as the Crime and Policing Bill 2025 (CPB) advances through Parliament. Currently through the House of Commons, and now in the House of Lords, the...more

A&O Shearman

UK regulatory reform: Emphasising individual accountability through remuneration

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The Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) are considering ways to enhance individual accountability, particularly among Senior Managers, by more fully integrating the regulatory...more

A&O Shearman

UK Financial Conduct Authority Dear CEO Letter for benchmark administrators

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The Financial Conduct Authority has published a Dear CEO Letter setting out its key concerns and priorities over the next two years for benchmark administrators. The FCA's supervisory priorities include: - corporate...more

A&O Shearman

UK bankers' remuneration: significant reform proposals

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The PRA and FCA are consulting on new proposals to simplify the UK remuneration regime and make it more proportionate for banks. Changes would reduce the number of material risk takers (MRTs) subject to the rules, simplify...more

Goodwin

The 2024 Mansion House Speech: Points for Private Fund Managers

Goodwin on

On 14 November 2024, Chancellor Rachel Reeves delivered her inaugural Mansion House 2024 speech, announcing a collection of reforms designed to drive growth and competitiveness in the financial services sector....more

Skadden, Arps, Slate, Meagher & Flom LLP

Fintech Focus Podcast | Managing a Workforce in a Regulated Environment

This episode of “Fintech Focus” picks up where our last episode “Growing a Workforce in a Regulated Environment” left off. Part Two delves further into workplace considerations for fintechs, and focuses on how they can manage...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fintech Focus Podcast | Growing a Workforce in a Regulated Environment

As growth-stage fintechs manage a rapidly increasing workforce, they are faced with onboarding senior-level hires within the scope of a complex regulatory environment in the U.K. On our latest “Fintech Focus” podcast, host...more

Seyfarth Shaw LLP

UK Criminal Liability Alert: Safeguarding Companies Operating in the UK From the Actions of Their Employees

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New criminal laws in the UK will make companies more vulnerable to criminal prosecution for the acts of their employees and agents than ever before. The Economic Crime and Corporate Transparency Act 2023 (“ECCTA”) introduces...more

BCLP

Caught in the crosshairs: How the PRA’s new Early Account Scheme impacts individuals

BCLP on

The Prudential Regulation Authority (“PRA”) has kicked-off 2024 by crystallising its new approach to enforcement. The key change is the introduction of the Early Account Scheme (“EAS”), which provides a mechanism for the...more

WilmerHale

The FCA Enforcement Club: Public Membership Soon to be Available...

WilmerHale on

“The first rule of enforcement club is that you do in fact talk about enforcement club”; so Therese Chambers, the UK Financial Conduct Authority’s (FCA) joint executive director of enforcement and market oversight, announced...more

A&O Shearman

Former Chief Executive of bank fined for failing to take “reasonable steps”

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The UK Prudential Regulation Authority (PRA) has fined the former CEO of Wyelands Bank GBP118,808 for various regulatory breaches, including that he failed to take reasonable steps to ensure the business for which he was...more

Latham & Watkins LLP

Bank of England Unveils Changes to the PRA’s Approach to Enforcement

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Recent changes to the PRA’s approach to enforcement show an increased focus on expediting the investigative process and incentivising early admissions. On 30 January 2024, the Bank of England (the Bank) unveiled a number...more

A&O Shearman

Impact of recent corporate criminal liability reforms for PE firms

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The new failure to prevent fraud offence and new ‘senior manager’ attribution test for corporate criminal liability contained in the Economic Crime and Transparency Act 2023 are relevant to private equity firms for two key...more

A&O Shearman

UK FCA and PRA proposals for improving D&I: Senior Manager responsibility and oversight

A&O Shearman on

The latest proposals for improving diversity and inclusion in the UK financial services sector, published by the Financial Conduct Authority and Prudential Regulation Authority, include changes that will impact Senior Manager...more

A&O Shearman

UK Financial Conduct Authority proposes new rules and guidance on non-financial misconduct

A&O Shearman on

The UK Financial Conduct Authority's consultation on diversity and inclusion (D&I) in financial services proposes new rules and guidance on identifying and taking action in relation to non-financial misconduct such as...more

K&L Gates LLP

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

K&L Gates LLP on

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

WilmerHale

A “New” City Bobby: Proactive FCA Supervision and Enforcement

WilmerHale on

In the build-up to his appointment as chief executive of the Financial Conduct Authority (FCA) in 2020, Nikhil Rathi stated that his vision for the regulator involved “a stronger, prompter approach to enforcement”. This...more

Morrison & Foerster LLP

Q&A: The Economic Crime and Corporate Transparency Act

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Headlines- • The Economic Crime and Corporate Transparency Act (the “Act”) is part of a wide legislative package to prevent abuse of UK corporate structures and tackle economic crime and received Royal Assent on 26 October...more

Morgan Lewis

UK Regulatory Changes on the Horizon? FCA, PRA, Treasury Launch Review of SMCR

Morgan Lewis on

The UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) published a discussion paper on 30 March 2023 seeking opinions on the Senior Managers and Certification Regime (SMCR). Concurrently, the UK...more

Latham & Watkins LLP

Consumer Duty Update: FCA Issues Dear CEO/Director Letters Setting Priorities for Sectors

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The letters ask senior management to prioritise implementing the Duty. On 3 February 2023, the FCA published Dear CEO/Director letters underscoring the immediate (i.e., during the implementation period up until 31 July...more

WilmerHale

Online Safety Bill - Update on Senior Manager Liability

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The Online Safety Bill (the “OSB”) is back on the UK Government’s legislative agenda, this time with an important update relating to criminal liability of senior managers. Following some political wrangling, back-bench MPs...more

Hogan Lovells

Consumer Duty: Moving into the next phase

Hogan Lovells on

Following the publication of the final rules, firms have been moving at pace to prepare implementation plans for boards to review, scrutinise and challenge, in order to achieve the 31st October deadline set by the Financial...more

Hogan Lovells

FCA final Consumer Duty rules and guidance published: time for firms to put the pedal to the metal

Hogan Lovells on

With the publication of the final rules there is now only a year to go before firms must comply with their Consumer Duty obligations. The FCA has emphasised that this must be a major cultural shift. While it’s good news that...more

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