Navigating the UK Senior Managers Regime

Private Equity Law Report
11 July 2019

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With the UK’s Senior Managers and Certification Regime (SMCR) coming into effect for PE in late 2019, Unquote sister publication Private Equity Law Report offers a comprehensive overview of the takeaways for UK managers

The UK’s Senior Managers and Certification Regime (SMCR) will soon be applied to the rest of the financial services industry, including PE sponsors. The SMCR introduces a heightened level of personal responsibility for senior managers, shifts the duty to certify control function staff onto regulated firms and establishes rules of conduct for all financial staff. A recent ACA Compliance Group (ACA) webinar, featuring Martin Lovick, ACA senior principal consultant; Josie Cooper, ACA consultant; and Dimitrios Sachinidis, ACA senior compliance analyst, provided a roadmap for navigating the transition to the SMCR. This article, the first in a two-part series, summarises the panelists’ insights on the genesis and extension of the SMCR, as well as the responsibilities of senior managers. The second article will explore the firm-based certification of certain other personnel, the imposition of rules of conduct on virtually all firm employees and steps PE managers can take toward compliance.

To read the first part of this report, including analysis of the considerations around non-UK entities, LLPs and duty of responsibility, head over to our sister publication Private Equity Law Report