Marking three years of the UK’s Senior Managers and Certification Regime
16 April 2019
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 force, industry trends and standards for best practice have emerged in key areas, such as fitness and propriety assessments, handovers between Senior Managers and regulatory references. Firms have also had to grapple with a number of post-implementation challenges along the way, especially in relation to the management of employee misconduct under the SMCR and the FCA’s more recent focus on ‘non-financial misconduct’.
In this briefing, we reflect on some of the key themes, trends and challenges that firms have faced since the implementation of the SMCR. These reflections draw on our extensive experience in this area, most notably our insights from having advised over 35 international banks in relation to the full range of implementation and post-implementation SMCR issues, as well as our work with various industry bodies on this topic.
Since its introduction in 2016, the SMCR has been closely observed by regulators in other jurisdictions. This has led to a number of other regulators introducing or proposing their own individual accountability regimes, most notably in Australia, Hong Kong and Singapore. These individual accountability regimes are also summarised in the briefing.