Conduct Rules for SM&CR Firms
Produced in partnership with Mark Compton and Lauren Smith of Mayer Brown International LLP

The following Financial Services practice note produced in partnership with Mark Compton and Lauren Smith of Mayer Brown International LLP provides comprehensive and up to date legal information covering:

  • Conduct Rules for SM&CR Firms
  • Overview
  • What are the Conduct Rules and what is their purpose?
  • Which firms and individuals do the Conduct Rules apply to?
  • Ancillary staff
  • Non-executive directors
  • Which activities do the Conduct Rules apply to?
  • From when do the Conduct Rules apply?
  • SM&CR banking Firms
  • SM&CR insurance Firms
  • More...

Conduct Rules for SM&CR Firms

BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see: Brexit and financial services: materials on the post-Brexit UK/EU regulatory regime. See also: Brexit and financial services—the temporary permissions regime (TPR) — Senior Managers & Certification Regime (SM&CR) and the TPR.


The Conduct Rules are one component of the broader Senior Managers & Certification regime (SM&CR), regulating qualifying individuals in the financial services sector. The Conduct Rules set minimum standards of individual behaviour in financial services. By applying the Conduct Rules to a broad range of staff, the Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA) aim to improve individual accountability and awareness of personal conduct issues across firms. The Conduct Rules will apply to almost all employees who carry out financial services activities, or linked activities, in a firm. Some Conduct Rules apply to nearly all employees, while others only apply to Senior Managers. This Practice Note considers both the FCA Conduct Rules contained in the FCA’s Code of Conduct for Staff sourcebook (COCON) and the

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