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ARTICLE · 15 FEBRUARY 2019

Senior Managers And Certification Regime: Major Changes On The Horizon

Ropes & Gray LLP
Ropes & Gray LLP
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Ropes & Gray LLP

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From 9 December 2019, all FCA solo regulated firms, as well as EEA and third country branches will be subject to the SMCR which will replace the current Approved Persons Regime ("APR").

United KingdomGovernment, Public Sector

What is changing?

  • From 9 December 2019, all FCA solo regulated firms, as well as EEA and third country branches will be subject to the Senior Managers and Certification Regime ("SMCR") which will replace the current Approved Persons Regime ("APR").

The SMCR aims to: 

  • make individuals more accountable for their conduct and competence;
  • encourage staff at all levels to take personal responsibility for their actions;
  • ensure firms and staff clearly understand and can demonstrate where responsibility lies.
  • Senior Managers will continue to be approved by the FCA. Employees that are not Senior Managers but are carrying out functions that could pose a risk of significant harm to the firm or its customers ("Certified Functions") will now be assessed as fit and proper by the firm.

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