Adam Jamieson

Partner, Ashurst

Adam is a partner in Ashurt’s Disputes Resolution. He specialises in advising financial services firms, listed companies and senior individuals involved in internal and regulatory investigations. Adam has significant experience of representing clients in regulatory enforcement investigations conducted by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA). Adam previously spent a year on secondment to the FCA’s Enforcement & Market Oversight Division. During his time at the FCA, Adam worked as an investigator on FCA and PRA investigations into both firms and individuals.

Contributed to

2

How should senior managers fulfil their personal regulatory duties under the SM&CR in relation to

Q&A

As a result of the conflict in Ukraine and the unprecedented imposition of sanctions which followed, in March 2022, the Financial Conduct Authority (FCA) laid down a clear marker that policing sanctions compliance is a high priority for it and stressed that ‘Where the FCA identifies failings in financial crime systems and controls we can impose restrictions and/or take enforcement action.’ This Q&A considers what this means for senior managers and the standard expected of them in order to discharge their personal regulatory duties under the Senior Managers and Certification Regime (SM&CR) in relation to sanctions compliance.

Financial Services

Avoiding unwanted attention—how senior managers should fulfil their personal regulatory duties

Checklists

Following the introduction of the Senior Managers & Certification Regime, the regulators’ appetite for pursuing enforcement cases against senior managers is ever increasing. Samantha Paul of Bryan Cave Leighton Paisner LLP, shares some insider tips on what steps senior managers should be taking to fulfil their personal regulatory duties and, ultimately, avoid becoming the subject of regulatory enforcement action.

Financial Services