In a recent speech, UK Financial Conduct Authority (FCA) Executive Director of Enforcement and Market Oversight,Mark Steward, outlined the key aims of the UK’s Senior Managers and Certification Regime (SMCR). The SMCR, Steward noted:
Steward explained how the SMCR encourages senior management to take ownership over their firms’ compliance: “By imposing personal liability, the regime uses self-interest – in this case the senior manager’s self-interest in avoiding liability – to avoid the bear pit of enforcement. This is a virtuous circle: what protects senior management from liability also reduces (though cannot guarantee) the risk of non-compliance more generally within firms.” The SMCR framework reflects the FCA’s focus on culture as a driver of conduct.
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