News & Analysis as of

SMCR Senior Managers Financial Services Industry

Akin Gump Strauss Hauer & Feld LLP

July – August Regulatory Round-Up

HM Treasury issued a consultation on 15 July 2025, “Regulatory Environment Pillar – Cross‑Cutting Issues,” which complements the Financial Services Growth and Competitiveness Strategy, addressing systemic improvements to the...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

A&O Shearman

UK Regulatory Academy: Monday 11-Friday 15 October 2021

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Between Monday 11 and Friday 15 October our UK Financial Services Regulatory team will host a series of foundational training sessions across a variety of UK regulatory topics and themes. ...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Clarifies FCA’s Powers Regarding Non-Financial Misconduct by Regulated Individuals

Key Points - The Upper Tribunal has issued the first ruling in relation to the FCA’s decision to sanction an individual following a conviction for a criminal offence which did not involve dishonesty. The FCA had sought...more

Hogan Lovells

SMCR Directory of certified and assessed persons – have you submitted your data?

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The Financial Conduct Authority (FCA) is contacting thousands of firms across various sectors that appear to have missed the 31 March 2021 deadline for submitting “Directory person” data. ...more

Morgan Lewis

SMCR: Full Implementation for Solo-Regulated Firms Delayed to 31 March 2021

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The UK Financial Conduct Authority recently published Policy Statement 20/12, which sets out the final rules on the extension of the Senior Managers and Certification Regime implementation deadlines for the certification...more

BCLP

SMCR Update – What best practice looks like

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The FCA has recently updated its Senior Managers and Certification Regime (“SMCR”) webpage for FCA solo-regulated firms. In particular, by reference to a list of positive/negative “indicators”, the FCA has set out further...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

Hogan Lovells

SMCR: UK FCA extends implementation periods for solo-regulated firms

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The UK Financial Conduct Authority (FCA) has extended the deadline for solo-regulated firms to undertake their first assessment of the fitness and propriety of their certified persons under the senior managers and...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

BCLP

2020 Funds First Update - February 2020

BCLP on

Welcome to our Funds First Update. In this briefing we set out an overview of some of the main developments and upcoming changes that we think will be of impact to fund managers, fund investors and to the funds sector as a...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

Morgan Lewis

UK Financial Conduct Authority Publishes Final Rules on Extending SMCR to Solo Regulated Firms

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Following its consultation earlier this year, the UK Financial Conduct Authority has now published a policy statement setting out its final rules for extending the Senior Managers and Certification Regime to solo-regulated...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

Latham & Watkins LLP

FCA Confirms SMCR Optimisations

Latham & Watkins LLP on

The FCA has published final rules confirming amendments to the SMCR, and final rules for solo-regulated firms. Key Points: ..The FCA has confirmed that the Head of Legal does not require approval as a Senior Manager,...more

A&O Shearman

The UK’s Expanded Senior Managers and Certification Regime: Key Issues and Action Plan for Brokers, Advisers and Asset Managers

A&O Shearman on

The expanded Senior Managers and Certification Regime (SM&CR), which comes into force on December 9, 2019, extends the framework regulating individuals charged with running certain financial institutions. The Banking SM&CR,...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

Morgan Lewis

FCA Issues Final Guidance on Key Issues Ahead of SMCR Extension

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The Financial Conduct Authority (FCA) has recently published its final guidance on statements of responsibilities, responsibilities maps, and its policy statement on the new FCA directory for financial services workers, ahead...more

BCLP

SMCR for FCA-solo regulated firms

BCLP on

The FCA recently released the latest in a long series of papers relating to the Senior Managers and Certification Regime (“SMCR”). FCA Consultation Paper CP19/4 sets-out new measures designed to “optimise” the SMCR ahead of...more

Hogan Lovells

The FCA consults on amendments to the SMCR: Excludes Head of Legal from the Senior Managers Regime and clarifies the scope of the...

Hogan Lovells on

On 23 January 2019, the Financial Conduct Authority (FCA) published a consultation paper (CP19/4) on optimising the Senior Managers and Certification Regime (SMCR). This paper consults on a range of proposed amendments and...more

Morgan Lewis

SMCR Extension: FCA Publishes ‘Near Final’ Rules, Sets Implementation Date

Morgan Lewis on

The Financial Conduct Authority and Prudential Regulation Authority published policy statements on 4 July on the extended Senior Managers and Certification Regime, setting out near final rules for solo-regulated firms and...more

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