SMCR Top 6
While there is a lot of process around SMCR. There are key changes to both attitudes, approach, and job roles that SMCR drives. Make sure you can demonstrate and signal the step change that the FCA is expecting by following…
Katharine Leaman
What makes a good compliance manual: Practical lessons from banking
Do you really need a compliance manual? Let’s get this clear from the beginning: there are no rules in the UK that say you must have a compliance manual. You are, of course, required to have good systems and controls,…
GameStop et al and Reddit – What are the compliance issues you should consider?
Quick Recap Assuming you are broadly aware of this issue here is a brief recap: Investors getting together on internet message boards (mainly on Reddit) and buying up stocks where they perceive short sellers have interest. This has resulted in…
Could FCA supervision be changing this year?
The Gloster and Parker reports show the FCA needs a fundamental overhaul and change in culture. Morale will likely be close to an all time low in an organisation that has struggled to attract and recruit experienced staff, something that…
Use it or Lose it: The FCA’s tougher new line on unused permissions
The rugby ball is at the back of the ruck, with the attacking team no longer making any forward progress. “Use it or lose it” shouts the referee, forcing the attacking team to play the ball or risk it being…
Principle 11: 6 tips for firms with no FCA supervisor
Principle 11 is important and the most frequently quoted principle in final notices. You must be open, honest, and transparent with the PRA and FCA. You need to be telling them what they would expect to know about. First FCA…
FCA Dear CEO to Wholesale Brokers: your checklist
After the global financial crisis the FCA was left no choice but to put all its focus and efforts on the banking sector. While FCA spent some time on sectors new to FCA regulation such as consumer credit, the majority…
Heightened risks of using third parties
Many regulated firms rely on third parties for services such as accounting, external audit or human resources, through to developing products and services, networking arrangements, payment processing, use of services provided by affiliates, joint ventures, and subsidiaries. The current operating…
5 lessons for compliance from GS and 1MDB
Earlier this year Goldman Sachs (GS) reached settlements with regulators in the US, UK, Singapore, and Hong Kong over 1MDB. On 22 October 2020, the Chief Executive Officer (CEO) of GS sent an email to all employees globally reflecting on…
Top ten risks of the new operating environment
The environment in which we are working has changed. This will change how you previously assessed risks. The FCA has been reminding us recently of the need to review your risk assessments in light of the new operating environment. But…