It’s been three years since SMCR was introduced into the banking and insurance sectors, but for some the journey is just beginning.
PwC Director Sarah Nield believes there is a lot to be learned from the first wave of the regime. She said, at our recent risk and compliance event in Manchester:
“Those that think this is a tick-box exercise make me somewhat nervous. I think there are complexities that will be really important to get right.
“The complexities come in where there are strong-willed people or group structures that mean it could be quite difficult for individuals to make a clear decision. They could be overruled, for example, or directed in a certain way, so being able to structure responsibilities and for individuals to be confident that they can deliver against these will be really important.”
SMCR is a very personally accountable regime - which will result in serious implications if you are the approved person in a non-compliant organisation. If you’re a compliance professional, it’s crucial that you get your stakeholders on board with your business proposal.
Here’s how to do it: