Key Benefits
- Understand the reforms and how they change senior manager, certification, and reporting processes
- Assess operational impact on onboarding, certification reviews, record keeping, and internal reporting
- Prepare your firm for implementation while maintaining accountability and aligning with future FCA and PRA developments
Do You Need to Attend This Course?
Senior Managers and Certification Regime Training is ideal for:
Senior Manager Functions (SMFs): individuals holding high-level responsibilities within their firms
Certified Persons (CPs): team members whose roles may cause "significant harm" to the firm or its customers
Oversight & Control Functions: essential for Risk, Compliance, HR, and Company Secretariat professionals
Technical Content
How we got to the SMCR Regime
Senior managers and certification regime training begins by explroing regulator expectations
Aims and Objectives of SMCR
Regime Categorisation – Core vs Enhanced
Senior Managers Regime
SMF categories
Prescribed responsibilities
Statement of Responsibilities (SoR)
Exercise – Reviewing the SoR
Duty of responsibility (collective vs. individual obligations)
Management Responsibility Maps
Defining Reasonable Steps
Case Study – Reviewing Reasonable Steps for an SMF
Certification Regime
Significant harm functions – who is in scope?
What am I certifying?
Assessing competency: measuring with consistency
When to assess Fitness & Propriety
Regulatory references – obligations and liabilities
Conduct Rules
Individual conduct rules: what they are and how they apply
Non-financial misconduct – effective September 2026 completes this section of SMCR conduct rules training
Breach Reporting
What constitutes a breach? Which breaches matter?
Are all disciplinary issues automatically conduct rule breaches?
FCA Breach reporting obligations
Exercise – an overheard conversation suggests a breach of conduct rules, which is challenged and escalated – who behaves appropriately in the ongoing discussions? (Includes SMFs, Certified Persons and Conduct Rules staff)
What we can Learn From the Implementation So Far
Key lessons from SMCR implementation and regulatory experience to date
Case Study – Jes Staley, Former CEO, Barclays
Common themes emerging from enforcement and supervisory activity
Understanding 'Reasonable Steps' and its growing role in regulatory investigations, including the FCA's ‘Dear CEO’ letters on overdraft arrangements, concludes training on senior management and certification regime
Training Objectives
SMCR training courses articulate the regulatory intent: explain the FCA’s strategic goals of accountability and transparency
Accurately Categorise Personnel: identify and distinguish between Senior Manager Functions (SMFs), Certified Persons (CPs), and Conduct Rules staff
Operationalise Accountability: draft and manage Statements of Responsibilities (SoR) and understand the "Duty of Responsibility"
Embed Conduct Standards: apply individual and senior manager conduct rules to real-world scenarios to foster a compliant firm culture
Manage Compliance Cycles: implement effective processes for fitness and propriety assessments, regulatory references, and breach reporting in this SMCR conduct rules training
Training Course Summary
Originally rolled out to the banking sector in 2016, the Senior Managers and Certification Regime (SMCR) has now been extended to over 40,000 firms.
The Financial Conduct Authority (FCA) tightened its rules, replacing the Approved Persons Regime with SMCR. This change affected all FCA-regulated firms, including non-UK firms with permission to carry out regulated activities in the UK, and focuses on three key areas:
The Senior Managers Regime
The Certification Regime
Conduct Rules
2026 sees changes to the regime and clearer guidance on non-financial misconduct. All aspects of SMCR conduct rules training can be customised for the specific operating models of your team.
Your trainer
Course Trainer · 30 yrs experience
- Compliance Courses
Involved with SMCR and its rollout to banking firms since 2016, SMCR conduct rules training is delivered by a specialist who shares the challenges he encountered and practical lessons he learned that remain relevant across regulated firms.
With over 30 years of experience in the financial services sector, he specialises in regulatory and financial crime compliance. Previously serving as the Head of Education for HSBC covering the UK and Europe, he was responsible for compliance learning during the bank’s Deferred Prosecution Agreement. This expert's career includes tenures at Barclays within the Private Clients and Wealth functions, as well as a Senior Vice President role at a major US-based bank, where they led Global Risk & Compliance training.
Highly knowledgeable about the senior manager & certification regime, he brings significant technical expertise from time spent at the Financial Conduct Authority in the Insurance Firms division. Whilst here, he served as the divisional expert on the rules and outcomes under the Training & Competence handbook. This trainer’s background in the second line of defence includes leading the Monitoring and Testing programme for a prominent UK Wealth Manager, who was provided with a comprehensive insight into practical application compliance frameworks.
With a delivery style informed by his extensive experience across retail, commercial, wholesale and private banking channels, this trainer has a proven collaborative track record. He’s worked with compliance, HR, and operational teams, enhancing regulatory understanding across private equity firms, investment houses, and wealth managers. A former member of the Investment Management Association Training & Education Committee delivers Senior Managers and Certification Regime training. This expert was also the recipient of the 2010 Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm”.
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