Building a whistleblowing culture: lessons from FCA enforcement cases
The FCA’s interest in whistleblowing culture extends well beyond the formal requirements of SYSC 18. Enforcement cases, thematic reviews, and the FCA’s continuing focus on non-financial misconduct have repeatedly revealed that the quality of an organisation’s whistleblowing culture is one of the most reliable early …
The Whistleblowing Champion (NED): who should fill the role and what they actually do
The Whistleblowing Champion is one of the most misunderstood appointments in the SMCR framework. Firms that are required to have one frequently confuse it with the executive whistleblowing function, underestimate what the role demands of the individual who holds it, and make appointments based on …
Best execution under COBS: what RTS 28 disclosures still require
Best execution has been a regulatory priority since MiFID II came into force in January 2018. The UK’s onshored version of RTS 28 — the Regulatory Technical Standard requiring investment firms to publish annual best execution reports — has created a disclosure obligation that many …
COBS suitability assessments: where firms most often fail FCA scrutiny
Suitability remains one of the FCA’s most consistent enforcement and supervisory priorities for investment firms. COBS 9 and 9A set out the requirements for personal recommendations and discretionary management, but the gap between what the rules require and what firms actually deliver in practice is …
Conduct rules breach reporting: what the FCA expects from your firm
The Notification Obligation in Plain Terms Under the Senior Managers and Certification Regime, firms that have taken disciplinary action against an employee for a breach of the Conduct Rules must notify the FCA. This notification obligation sits within the FCA’s Supervision manual (SUP 15) and …
Conduct rules training: how to deliver something that actually changes behaviour
Why Most Conduct Rules Training Fails The FCA requires firms to train all Conduct Rules staff on the Individual Conduct Rules and to keep records evidencing that training has been delivered. Most firms meet this requirement. Very few meet it in a way that produces …
Hiring under SMCR: practical interview questions for senior manager candidates
Why Interviewing Under SMCR Is Different Recruiting a Senior Manager into an FCA-regulated firm is not simply a question of finding the most capable candidate. Under the Senior Managers and Certification Regime (SMCR), every appointment to a Senior Management Function (SMF) carries personal regulatory accountability …
SMCR Phase 1 Reform 2026: what the FCA’s policy statement actually changes
Why the FCA Is Reforming SMCR The Senior Managers and Certification Regime (SMCR) has been the framework for individual accountability in UK financial services since 2016 for banks and 2019 for solo-regulated firms. After more than five years of full operation, HM Treasury commissioned a …
SMCR vs APR: what was lost when the Approved Persons Regime was retired
The Regime That SMCR Replaced For twenty years, the Approved Persons Regime (APR) was the FCA’s primary framework for holding individuals at regulated firms to account. Introduced under the Financial Services and Markets Act 2000, the APR required firms to obtain FCA approval for anyone …
SMCR for Limited Scope firms: what changes if you’re a Limited Scope firm
What Is a Limited Scope Firm Under SMCR? When the Senior Managers and Certification Regime (SMCR) was extended to solo-regulated firms in December 2019, the FCA recognised that a single framework applied uniformly to every authorised firm would be disproportionate. The result was a three-tier …
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