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Nov 01, 2015

Implementation Issues Arising from the Revised UK Senior Manager and Certification Regime

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The UK Government recently announced that it would introduce a new statutory duty of responsibility on senior managers in all financial institutions and repeal the presumption of responsibility that would have applied to senior managers in banks and large investment firms. Senior managers will need to take reasonable steps to prevent a significant breach of a regulatory requirement in their area from occurring or continuing. The onus will be on the regulators to prove that the individual did not take reasonable steps. This note discusses the practical implications for firms and the individuals working in them of the senior managers regime as now proposed.

View memo, Implementation Issues Arising from the Revised UK Senior Manager and Certification Regime

Authors and Contributors

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5528

+44 20 7655 5528

London

Thomas Donegan

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5566

+44 20 7655 5566

London

Reena Agrawal Sahni

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7324

+1 212 848 7324

New York

Jo Rickard

Of Counsel

Litigation

+44 20 7655 5781

+44 20 7655 5781

London

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York

Timothy J. Byrne

Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7476

+1 212 848 7476

New York

Kolja Stehl

Counsel

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5864

+44 20 7655 5864

+49 69 9711 1623

+49 69 9711 1623

London

Sam Whitaker

Counsel

Compensation, Governance & ERISA

+44 20 7655 5954

+44 20 7655 5954

London

Steven Blau

Associate

Financial Institutions Advisory & Financial Regulatory

+1 212 848 8534

+1 212 848 8534

+1 416 360 2154

+1 416 360 2154

New York

Jenny Ding Jordan

Associate

Financial Institutions Advisory & Financial Regulatory

+1 212 848 5095

+1 212 848 5095

New York

Oliver Linch

Senior Associate

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5715

+44 20 7655 5715

London

Jennifer D. Morton

Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 5187

+1 212 848 5187

New York

Ellerina Teo

Senior Associate

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5070

+44 20 7655 5070

London