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UK Senior Managers and ‘reasonable steps’: Clarity at last?


05 October 2016

​Last week the UK Financial Conduct Authority (FCA) published new draft guidance on the meaning of ‘reasonable steps’ for the purposes of the Senior Managers Regime.

The concept of ‘reasonable steps’ is not a new one when it comes to senior management in financial institutions in the UK. Under the old approved persons regime, individuals performing Significant Influence Functions were required to take ‘reasonable steps’ to discharge their regulatory obligations.
For more information on the FCA’s latest draft guidance, and our views on it, please click here to access our commentary on Allen & Overy’s Investigations Insight blog.

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