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One Year On, Banking Accountability Regime Gears Up

March 6, 2017, Law360

Charlotte Hill is quoted in a Law360 article regarding the start of the Senior Managers and Certification Regime which allows the Financial Conduct Authority to trace responsibility up to the highest levels within banks and other financial institutions when there is evidence of misconduct. According to Hill, the introduction of criteria to ensure certain employees are suited to do their jobs is familiar ground in banking circles, but firms cannot afford to pay lip service to the new demands. "What is new is the evidence that relevant firms have to collect as part of their process for ensuring that candidates are 'fit and proper' and meet the required standards.” 

"It is a big change from the time of the financial crisis of 2008," she says. "But one that has been coming in gradually over time, so no one could pretend to be surprised by it." 

"The FCA is still consulting on the exact requirements, but firms should be starting to think about what they will need to be doing now," Hill adds. "There is quite a bit of work that needs to be done, with a lot more documentation required, such as the new requirements around responsibility maps."


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