The COVID-19 outbreak brings into play a number of important
regulatory requirements of which financial institutions need to be
mindful. These include the FCA's Principles for Businesses, the
PRA's Fundamental Rules, the Threshold Conditions in the
Financial Services and Markets Act 2000 and the FCA's rules and
guidance in the Senior Management Arrangements, Systems and
Controls sourcebook.
The regulatory requirements concerning operational resilience
have, in particular, been brought into even sharper focus.
Financial institutions are reviewing the consultations that both
regulators issued before Christmas. A key component of the
operational resilience piece is outsourcing and third-party risk
management, particularly as financial institutions are increasingly
reliant on technology provided by third parties. Again the
regulators are currently consulting on updating their rules.