Compliance Due Diligence on a Regulated Target
When a finance leader runs diligence on an acquisition, the financial information gets taken apart. Revenue is tested for quality, working capital is normalised, the pipeline is challenged, and every material contract is read. If the target is FCA-regulated, the compliance function usually gets a …
What Adequate Compliance Resourcing Costs
Every regulated firm has a compliance budget. Very few finance leaders can explain how the number was arrived at, beyond its being roughly what it was last year plus inflation. That is a problem, because unlike most cost lines, this one has a regulatory floor. …
Challenging the Compliance Monitoring Report
In most regulated firms, the compliance monitoring report is the least challenged document in the board pack. The finance numbers get picked over line by line. The monitoring report gets a nod and a minute recording that it was received. That is not because boards …
The MLRO Annual Report: What the Board Should Expect
The board’s most important window into financial crime risk Once a year, the Money Laundering Reporting Officer of an FCA-regulated firm should give senior management and the board a report on how well the firm’s anti-money laundering systems and controls are working. For many boards …
The First 90 Days of a New Head of Compliance
Why the first 90 days matter so much A new Head of Compliance takes on personal accountability from the day they start performing the SMF16 Compliance Oversight function. Under the Senior Managers and Certification Regime, the duty of responsibility means they can be held to …
How New FCA Rules Are Changing Compliance and MLRO Hiring
Three rule changes, one pressure point In the space of three months in 2026, the FCA changed the rules in three areas that rarely get discussed together. In April it reformed the 12-week rule for covering senior manager absences. In May its strengthened safeguarding regime …
When to Hire Your First In-House Head of Compliance
From consultancy support to your own compliance leader Most small FCA-regulated firms do not start with an in-house Head of Compliance. They come through authorisation with the help of a compliance consultancy, which drafts the policies, sets up the monitoring programme and, in many cases, …
SMF16 and SMF17: One Person or Two?
The question almost every smaller regulated firm faces Every Core and Enhanced firm under the Senior Managers and Certification Regime needs someone to hold the SMF16 Compliance Oversight function and, where the Money Laundering Regulations apply, someone to hold the SMF17 Money Laundering Reporting function. …
FCA Non-Financial Misconduct Rules: 1 Sept 2026
From 1 September 2026, non-financial misconduct — serious workplace bullying, harassment and violence — becomes an explicit Conduct Rule matter for around 37,000 additional UK financial services firms, not just banks. For businesses making senior appointments at FCA-regulated firms, the practical question this raises isn’t …
SMF Personal Liability: What Senior Managers Risk
Every firm authorised by the FCA has to allocate its Senior Management Functions to named individuals. On paper, that looks like an org chart exercise — someone becomes SMF1, someone becomes SMF16, someone becomes SMF17. In practice, it is one of the more consequential decisions …
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