Nicola Boulton quoted in CDR News article on Senior Managers and Certification Regime

Aug 4, 2015

Nicola Boulton has been quoted today in an Commercial Dispute Resolution News article on the forthcoming Senior Managers and Certification Regime (SMR). The SMR comes into force in March 2016 and replaces the Financial Conduct Authority’s existing Approved Persons Regime which has been criticised for its failure to impose accountability on senior individuals at banks in the wake of the LIBOR market-rigging scandal.

The article questions the efficacy of the SMR. One concern is that it could lead to a defensive culture within banks whereby overly cautious managers create a paper trail to justify every decision. Nicola suggests that: “going through a more bureaucratic process is not necessarily going to get us better decision-taking; it will take us to decision taking that can be defended by pieces of paper.

Byrne and Partners recently acted for former JPMorgan Chase employee Bruno Iksil, who was cleared of breaching the FCA Principles for Business in a highly publicised decision of the FCA’s Regulatory Decisions Committee.

The full CDS News article is available to subscribers here: http://www.cdr-news.com/categories/regulatory/5730-senior-managers-regime-roaring-lion-paper-tiger