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 …
FATF: What FCA-Regulated Firms Need to Know
Financial Action Task Force directly, yet its work shapes the anti-money-laundering obligations every regulated firm has to meet. FATF sets the global standards that flow into UK law and, ultimately, into a firm’s customer due diligence and financial crime controls. This article explains what FATF …
ESG Compliance Officer: The Role and What FCA Firms Need
ESG Compliance Officer: The Role and What FCA Firms Need Sustainability and ESG have moved from a reputational concern to a regulated compliance obligation, and firms have responded by creating a role that barely existed a few years ago: the ESG Compliance Officer. This article …
SMF3 vs SMF1: Executive Director vs CEO Under SMCR
SMF3 vs SMF1: Executive Director vs CEO Under SMCR SMF1 and SMF3 are two of the most senior controlled functions under the Senior Managers and Certification Regime, and the difference between them is frequently misunderstood. Both are held by senior executives; both carry personal accountability. …
CRO vs CCO: How the Two Functions Differ at FCA Firms
CRO vs CCO: How the Two Functions Differ at FCA Firms The Chief Risk Officer and the Chief Compliance Officer are often confused, sometimes combined, and frequently misunderstood — including by firms hiring for them. Both are second-line functions, both are senior, and at FCA-regulated …
Head of Internal Audit: Career Path at FCA-Regulated Firms
Internal audit is the third line of defence — the function that gives the board independent assurance that the first and second lines are actually working. At many FCA-regulated firms the Head of Internal Audit holds SMF5, a senior management function. This article sets out …
Consumer Duty: What Firms Have Learned
Consumer Duty One Year On: What Firms Have Learned The Consumer Duty came into force on 31 July 2023 for open products and a year later for closed ones. Enough time has now passed — and enough FCA review activity has followed — to see …
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