The U.K. Senior Managers Regime: Certification Regime and Conduct Rules (Part Two of Two)

The U.K. is adopting the Senior Managers and Certification Regime (SMCR) that will, among other things, introduce heightened levels of personal responsibility and accountability for private fund managers. A recent ACA Compliance Group (ACA) webinar provided a roadmap for PE sponsors to navigate the widespread adoption of the SMCR by the entire financial services industry on December 9, 2019. The program featured Martin Lovick, ACA senior principal consultant; Josie Cooper, ACA consultant; and Dimitrios Sachinidis, ACA senior compliance analyst. This article, the second in a two-part series, summarizes the panelists’ insights on the firm-based certification of certain other personnel, the imposition of rules of conduct on virtually all firm employees and steps fund managers – including PE sponsors – can take toward compliance. The first article reviewed the genesis and extension of the SMCR, as well as the responsibilities of senior managers. For additional commentary from ACA, see “Developing a 2018 Compliance Budget: How Investment Advisers Can Make the Most of Limited Resources” (Dec. 21, 2017); and “Challenges and Solutions in Managing Global Compliance Programs” (Oct. 5, 2017).

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