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 …
The FCA’s Annex 1 Crackdown: What It Means for Hiring
A category of firm that most people outside financial services have never heard of has suddenly found itself under real regulatory scrutiny. Annex 1 firms — non-bank lenders, leasing companies, money brokers and similar businesses registered with the FCA for anti-money-laundering supervision — spent years …
Wise’s US Licence Refusal: The Senior Hiring Lesson for Regulated Firms
When a regulator refuses an application, the failure is not always in the systems. In the case of Wise’s US bank charter, the regulator questioned whether the proposed management team had the right experience. That is a recruitment problem, and UK firms preparing FCA applications …
TNFD vs TCFD: How the Two Frameworks Relate
TNFD vs TCFD: How the Two Frameworks Relate TNFD and TCFD are often mentioned together and just as often confused. They are related by design — one was built on the model of the other — but they cover different things and sit at very …
Accredited Member of GBC
Accredited Member of LWF
Carbon Offset via TreeNation
