Jurisdiction(s):
United Kingdom

FCA/PRA SM&CR: Senior Managers’ Checklist for Initial Assessment, Ongoing Oversight and Incident Response to Discharge Personal Regulatory Responsibilities and Minimise Enforcement Risk

Published by a LexisNexis Financial Services expert

Checklists

This Checklist outlines pragmatic measures for senior managers falling under the FCA and PRA’s Senior Managers and Certification Regime (SM&CR), supporting them in meeting their individual regulatory duties and, in turn, mitigating the prospect of enforcement action.

What do senior managers need to do initially when commencing their role?

Upon starting a new position in a financial institution, senior managers ought to complete a recorded, early review of the risk management framework relevant to their business area, within the first two to three months. For the avoidance of doubt, regardless of the scale of the firm’s compliance or risk function, accountability for regulatory compliance—including the design and performance of the risk management framework—also rests with the senior manager accountable for that part of the business. That review should include setting up meetings with those in the business who best understand how the area was run before the senior manager arrived (ideally including the predecessor), as well as with Compliance, Risk Management, Internal Audit and HR. These steps support fulfilment of personal regulatory duties and limit enforcement risk over time...

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Samantha Paul

Bryan Cave Leighton Paisner

Samantha is a skilled lawyer with extensive private practice and in-house experience of handling complex, multi-jurisdictional regulatory and criminal investigations, English and overseas litigation, and related advisory work.Samantha brings this experience to her role as BCLP’s Senior Knowledge Lawyer for the Financial Services Disputes and Investigations and White Collar Practice Group. Her role includes providing expert legal knowledge, training and thought leadership, as well as promoting particular expertise to existing and potential clients. She also assists the teams with strategy, development and innovation initiatives.Before joining BCLP, Samantha worked for a number of years in the Financial Services Litigation team at another international law firm, where her experience included acting on a long-running multi-jurisdictional investigation in relation to LIBOR for a well-known bank.Samantha then moved in-house, serving as Senior Counsel in the Litigation and Regulatory Enforcement team at an international investment bank. Her in-house...

Web page updated on 20/05/2026

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