Senior Managers and Certification Regime

The Senior Managers and Certification Regime (SMCR) is part of the UK regulators’ drive to improve culture, governance and accountability within financial services firms. It aims to deter misconduct by improving individual accountability and awareness of conduct issues across firms.

Banks and PRA-designated investment firms have been subject to the SMCR since March 2016 and dual-regulated insurers are currently subject to the Senior Insurance Managers Regime (SIMR). The SMCR will be extended to cover all PRA- and FCA-regulated insurance and reinsurance firms on 10 December 2018 and all other FSMA-authorised firms on 9 December 2019.

We have an unparalleled depth and breadth of expertise in advising on the SMCR, and related governance and risk management issues, in both the advisory and contentious context. We were instructed by over 15 global banks and insurers in relation to the implementation of the SMCR and SIMR, are advising a number of firms on the proposed extension and continue to have regular dialogue with regulators and the industry in relation to the operation of the regulators' individual accountability regimes.

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