Regulatory action against Senior Managers
Produced in partnership with Lucy Kerr of RPC and Jonathan Cary

The following Financial Services practice note produced in partnership with Lucy Kerr of RPC and Jonathan Cary provides comprehensive and up to date legal information covering:

  • Regulatory action against Senior Managers
  • Introduction
  • The SM&CR under the FCA and PRA regimes
  • Which individuals can the regulators take action against?
  • When will the regulators investigate senior management?
  • What sanctions can the regulators impose on senior managers?
  • Practical issues to consider when an investigation is opened into a senior manager
  • Recent investigations into senior managers
  • Other considerations
  • Criminal proceedings
  • More...

Regulatory action against Senior Managers

Lexis®PSL Financial Services FCA/PRA Enforcement Database: This incorporates detailed information on all substantive FCA and PRA Final Notices and, where available, Decision Notices from 2014 to 2020. The Database, available here, may be searched and filtered by rule breach, keyword, sector, date, seriousness, aggravating and mitigating factors, financial penalty, and other actions such as appeals. By selecting ‘individual’ in column E, detail on all notices and decisions relating to enforcement against individuals is available.


The regulation of senior managers in the financial services industry has gone through a seismic shift in recent years. The Senior Managers and Certification Regime (SM&CR), which was first introduced to the banking industry in March 2016, has since been expanded to encompass insurers (in December 2018) and since December 2019, it also applies to almost all other financial services firms. At present, approximately 49,000 firms and their senior managers are subject to this regime.

The intention behind the creation of the SM&CR was to encourage a fundamental change in the compliance culture across the financial services industry following the global financial crisis. The SM&CR seeks to strengthen the individual accountability of senior managers by making it easier for the Financial Conduct Authority (FCA) and/or the Prudential Regulation Authority (PRA) to hold them to account for the failings of their firms. The SM&CR also

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