SYSC 4: How the FCA Expects Governance to Be Structured
SYSC 4 is the chapter of the FCA’s Senior Management Arrangements, Systems and Controls sourcebook that sets out how the FCA expects regulated firms to govern themselves. It is not a bureaucratic checklist — it is the FCA’s articulation of what effective governance actually looks …
FCA Gateway: What a Strong CEO and Chair Statement Needs
The CEO and Chair Statements are the FCA’s window into whether the firm’s leadership genuinely understands its regulatory obligations — or whether it is relying on a compliance function and legal advisers to navigate a process the senior management have not engaged with themselves. As …
Variation of Permission: When You Need One and How to Apply
Varying a Part 4A permission is one of the most common post-authorisation regulatory steps for growing FCA-regulated firms — and one of the most frequently misunderstood. Getting it right means understanding which activities actually require a VoP and submitting a well-prepared application. A Variation of …
FCA Section 55 Cancellation: Triggers and How to Respond
A Section 55 cancellation is one of the most serious regulatory actions the FCA can take — it removes the firm’s permission to carry on regulated activities. Understanding what triggers it, how the process unfolds, and what options are available is essential for any regulated …
FCA Application Timelines: Realistic Expectations for 2026
The FCA’s statutory six-month deadline is the ceiling, not the expectation. In 2026, most well-prepared applications from straightforward firm types are determined in three to four months. Applications with gaps, novel business models, or incomplete SMF submissions routinely run to five or six months — …
From TCF to Consumer Duty: What Changed in the Obligation
Treating Customers Fairly and Consumer Duty cover much of the same ground. But the differences in how each obligation operates — in governance, evidencing, enforcement and the standard of outcome expected — are material. Firms that treat Consumer Duty as TCF with a new name …
Vulnerable Customers in Wealth Management: A Practical Guide
Identifying vulnerable clients is one of the most technically and ethically demanding obligations the Consumer Duty places on wealth managers. Done well, it protects clients at the moments they most need it. Done as a compliance exercise, it generates documentation that satisfies no one. The …
EDD Triggers: High-Risk Countries, Sectors and Products
Enhanced due diligence is not a catch-all for any customer the firm is uncertain about — it is a defined set of measures triggered by specific risk factors. Knowing precisely when EDD is required, and what it must involve, is fundamental to a compliant and …
Transaction Monitoring Tuning: Balancing Detection and Noise
Transaction monitoring is only as good as its calibration. A system generating hundreds of unactionable alerts daily is not more effective than one generating ten meaningful ones — it may be less effective, because alert fatigue erodes the quality of the human review that makes …
MLR 2017 Firm-Wide Risk Assessment: Structure and Content
The firm-wide risk assessment is the foundation of every AML compliance programme. Without a well-structured, specific and regularly updated risk assessment, a firm’s AML controls — however individually sound — are built on uncertain ground that will not withstand FCA scrutiny. Regulation 18 of the …
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