Compliance officers and breach reporting—SRA 2011 regime and SRA 2019 regime compared
Compliance officers and breach reporting—SRA 2011 regime and SRA 2019 regime compared

The following Practice Compliance practice note provides comprehensive and up to date legal information covering:

  • Compliance officers and breach reporting—SRA 2011 regime and SRA 2019 regime compared
  • Compliance officers
  • Reporting compliance breaches
  • General reporting obligation on all regulated persons and firms
  • Specific reporting obligation on compliance officers

This Practice Note contrasts the requirements in the SRA’s 2011 and 2019 regimes in relation to compliance officers (COLPs and COFAs) and breach reporting. For more detailed guidance, see Practice Notes: Compliance Officers 2019—law firms and Breach reporting 2019—law firms.

Compliance officers

The table below reflects requirements applying to compliance officers. It does not deal with detailed SRA requirements in relation to approval of compliance officers or exceptions to the requirement to have compliance officers.

SRA Handbook 2011SRA Standards and Regulations 2019
An authorised body must at all times have an individual:
—who is the sole practitioner, a manager or an employee of the authorised body
—who is designated as its COLP and who is designated as its COFA
—who is of sufficient seniority and in a position of sufficient responsibility to fulfil the role, and
—whose designation is approved by the SRA
SRA Authorisation Rules 2011, r 8.5
An authorised body must at all times have an individual who is designated as its COLP and an individual who is designated as its COFA, and whose designations the SRA has approved.
SRA Authorisation of Firms Rules, r 8.1
An authorised body must have suitable arrangements in place to ensure that its compliance officers are able to discharge their duties in accordance with these rules.
SRA Authorisation Rules 2011, r 8.5
Have effective governance structures, arrangements, systems and controls in place

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