Sanctions Screening for Payment Firms: Speed vs Accuracy
For payment firms processing thousands of transactions per day, sanctions screening creates a direct tension between two non-negotiable requirements: screening must be comprehensive enough to catch genuine matches, and it must be fast enough not to disrupt the payment processing that customers depend on. Sanctions …
Tier 1 and Tier 2 Conduct Rules: Who They Apply To
The SMCR Conduct Rules apply to virtually everyone working at an FCA-regulated firm — but they do not apply equally. The distinction between Tier 1 (Individual Conduct Rules) and Tier 2 (Senior Manager Conduct Rules) determines what each person is required to do and, critically, …
Reasonable Steps Under SMCR: What the FCA Looks For
“Reasonable steps” is the central concept of SMCR personal accountability — and the FCA’s track record in enforcement shows exactly what it means in practice. This is not an abstract standard. The FCA assesses it against concrete questions about what the SMF holder knew, what …
Statement of Responsibilities: Drafting Tips for New SMFs
The Statement of Responsibilities is the document that defines what you are personally accountable for as a Senior Manager. Done well, it protects you and the firm. Done poorly, it creates ambiguity that the FCA will exploit if something goes wrong. Every proposed SMF holder …
Annual Certification: Practical Steps for Certified Persons
Annual certification is a genuine compliance obligation — not a bureaucratic formality. Firms that treat it as a tick-box exercise, and individuals who wait passively for their employer to manage it for them, both regularly find themselves in difficulty when the FCA asks questions. Under …
Senior manager handover: best practice when SMFs leave
Senior manager handover: best practice when SMFs leave When a Senior Manager leaves an FCA-regulated firm, the event triggers a series of regulatory and governance obligations that go significantly beyond a standard employment notice period and handover. The departing senior manager must be withdrawn from …
SMF24 in growing firms: why the Chief Operations Function matters
SMF24 in growing firms: why the Chief Operations Function matters The SMF24 Chief Operations Function is one of the less prominent Senior Manager designations — less widely discussed than the SMF2 CFO function or the SMF16 compliance oversight role, and less specifically defined in the …
Allocating Prescribed Responsibilities by Firm Type
Allocation of Prescribed Responsibilities: practical examples by firm type Prescribed Responsibilities are specific regulatory obligations that the FCA requires to be allocated to a named Senior Manager in every FCA-regulated firm. Unlike the Senior Manager Functions themselves — which define the areas a senior manager …
Career Paths to SMF16: Positioning for Compliance Oversight Roles
Career paths to SMF16: how to position for Compliance Oversight roles The SMF16 Compliance Oversight Function is one of the most technically demanding senior manager designations in the FCA’s SMCR framework. The individual holding SMF16 is personally accountable to the FCA for the adequacy of …
SMF2 vs CFO: when the FCA function differs from the corporate title
SMF2 vs CFO: when the FCA function differs from the corporate title The SMF2 Senior Manager Function designates the individual who has overall responsibility for a firm’s financial resources and financial reporting to the FCA. In most FCA-regulated firms, the SMF2 is held by whoever …
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