We thought it appropriate to remind firms that the SM&CR comes into effect on 9 December 2019 for FCA solo-regulated firms. ATEB has published several newsletter articles outlining the requirements – start here if you want read our most recent article.
If you have not yet started your preparations for SM&CR – or even if you have – you might find the ATEB SMCR Guide for firms useful. An accompanying toolkit comprising checklists and document templates is also available.
Firms should ensure that all preparatory work has been, or is being, undertaken. In particular, firms must ensure that awareness training on the Conduct Rules has been undertaken and can be evidenced by 9 December 2019. The training should cover the first and second tier rules with Senior Managers and the first tier rules with all Certification Staff.
Firms have until 9 December 2020 to roll out first tier training to all other staff.
ATEB have produced a training module to help firms deliver Conduct Rules training. This, and our guide and toolkit can be found within the members’ area of our website.
Advising non-UK clients
Alistair MacDougall Compliance Conduct, EEA, email, EU, FCA, MiFID, passport, PI, vulnerable
Despite the fact that the UK ceased to be a member of the EU/EEA almost a year ago, we are still asked for advice around how a UK firm can take on a new non-UK client or continue to deal with such clients that the firm had pre-BREXIT. We have written before about the general […]