Is your firm prepared for the full implementation of the SM&CR? Is your staff trained on the Conduct Rules? If you require any assistance please contact Scott Robert on 0161 914 5727.

See Scott Robert’s regulatory roundup for the second half of March:

  1. The second phase of the SM&CR implementation period ends this week:
    The Senior Managers & Certification Regime (SM&CR) is due for full implementation by March 31st Originally, the deadline was set for December 2020, however, the Financial Conduct Authority (FCA) decided to push this back due to the disruption caused by the Coronavirus pandemic. By the end of the month, regulated firms are expected to have trained all relevant staff members on the FCA’s Conduct Rules and have conducted Fit and Proper Assessments on any individuals performing Certification Functions. Firms are also expected to complete Directory Persons notifications through Connect to provide the FCA with information on these key individuals. For more information see the FCA’s webpage here. Would you like assistance with implementing SM&CR to your firm? Scott Robert can help with training and other materials, contact us today for our assistance.


  1. The FCA has launched their first criminal proceedings under the Money Laundering Regulations 2007 against a bank, NatWest plc:
    In an unprecedented move, the FCA has launched criminal proceedings against NatWest plc for ‘substantial failings’ for monitoring and preventing money laundering by its customers. The FCA alleges that NatWest failed to adhere to multiple regulations in the period between November 2011 to October 2016 and notes roughly £365 million was paid into customer accounts of which £264 million was in cash. The proceedings are due to start on April 14th 2021 and mark the first time that the FCA has taken criminal proceedings against a bank or criminally charged any firm under the Money Laundering Regulations 2007 (MLR). See the FCA’s press release here.


  1. The FCA has increased the implementation period for the proposed rule changes in the consultation paper CP20/19 on general insurance pricing:
    The FCA has noted that the majority of responses to its consultation paper CP20/19 on general insurance pricing practices pointed out that the implementation period was insufficient to adapt to the proposals within the paper. The responses explained the package of remedies that the FCA consulted on would require sweeping business changes and re-coding of IT systems. The FCA has thus decided to push back the implementation deadline to September 2021 for the system and controls rules and to finalise these rules by May 2021. The FCA has proposed to extend the pricing and auto-renewal remedies and reporting implementation deadline to the end of 2021, giving firms more time to adapt. The consultation paper can be found here.
  2. The FCA has that found younger investors are more likely to invest in high-risk crypto assets which are high-pressured selling and potentially unsuitable for them:
    Research into investor habits and profiles has revealed to the FCA that young investors are far more likely to invest in crypto-assets with the investment sometimes not being suitable to the individual investor. The FCA highlighted concerns that nearly two-thirds of investors admitted that if their investment returned as a loss, this would have an adverse impact on their future or current lifestyle. The FCA also saw areas of concern within the motivations for investing as 38% of the investors surveyed did not put a single functional reason in their top 3 reasons to invest. Young investors, according to the FCA, are the most likely to have low financial resilience hence being the most vulnerable to any loss. The FCA has, in response to its findings, launched its ‘digital disruption’ campaign to prevent investment harm which interrupts investor’s journeys and drive them to alternative webpages which aim to educate and allow investors to better weigh up their choice before investing. The FCA findings can be found here.
  3. The FCA has launched a compare to raise awareness and encourage whistleblowing with its regulated firms:

Regulated firms are being encouraged to share amongst its employees published materials from the FCA informing and the detailing the whistle blowing process to the FCA. The FCA wish to demonstrate whistle-blowers can confide ‘with confidence’ and ‘in confidence’. As such the FCA have placed more resource to support increased whistle blower interaction and more staff to the whistle-blowing team. The FCA has reminded firms that firm culture and governance remains a priority and that firms should appoint a ‘whistleblowing champion’ within the firm to appropriately manage any whistle-blowing concerns. FCA press release can be found here. Do you require assistance with your whistle-blowing policy or would you like any further guidance, Scott Robert can help.

Please visit our website to see how we can support you or if you have any questions regarding the information in this newsletter, please contact us today on 0161 914 5727 or email enquires@scottrobert.co.uk.

Scott Robert.