The U.K. Senior Managers Regime: Certification Regime and Conduct Rules (Part Two of Two)

A recent ACA Compliance Group (ACA) webinar provided a roadmap for fund managers to navigate the transition to the U.K. Senior Managers and Certification Regime (SMCR), which will apply to the financial services industry in its entirety on December 9, 2019, and introduces, among other things, heightened levels of personal responsibility and accountability. The program featured Martin Lovick, ACA senior principal consultant; Josie Cooper, ACA consultant; and Dimitrios Sachinidis, ACA senior compliance analyst. This article, the second in a two-part series, summarizes the panelists’ insights on the firm-based certification of certain other personnel, the imposition of rules of conduct on virtually all firm employees and steps fund managers can take toward compliance. The first article covered the genesis and extension of the SMCR, as well as the responsibilities of senior managers. For additional commentary from ACA, see “Developing a 2018 Compliance Budget: How Investment Advisers Can Make the Most of Limited Resources” (Dec. 21, 2017); and “Challenges and Solutions in Managing Global Compliance Programs” (Oct. 5, 2017).

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