SM&CR is just forms and box-ticking, right?
Well, no. And this assumption is a guaranteed way to undermine your implementation of the new regime.
The spirit of SM&CR is that it’s a holistic rethink of the compliance culture in your firm. If you think of it as just a singular task you’re almost certainly going to miss things out.
You need to make sure SM&CR is embedded deep into your governance framework. Committing to it in the foundations of how you work will encourage staff to commit to it too. And staff who truly understand the reasons for the regulation will act appropriately, meaning you’re less likely to be left exposed to risks.
It’s no coincidence that SM&CR is all about cultural change when a priority for the FCA continues to be culture and governance. SM&CR is an extension of this general focus.
So what can you do about this?
The best thing you can do is act now. Take immediate steps to adapt your processes, and embed the new regime into your governance arrangements, systems and controls. Pay particular attention to your board and management structure.
Consider any potential conflicts of interest that may arise as part of the embedding process.
The sooner you embed the new regime into your processes, the quicker you’ll be able to identify weaknesses and issues. Then you can make the changes you need to get on top of the new regulation as soon as possible.
We’ve made his sound really simple, but we know it’s not that easy. Luckily we’re here to help you plan and implement your approach, assuring you that you’re fully ready for when SM&CR comes into force on the 9th December 2019.