On 26 July 2019, the UK Financial Conduct Authority published a policy statement, PS19/20, setting out its final rules and guidance on:
– the extension of the Senior Managers & Certification Regime to FCA solo-regulated firms and a new directory; and
– a new directory of individuals working in financial services.
For in-house lawyers, and importantly, a Head of Legal is excluded from the requirement to be approved as a Senior Manager.
The new SMCR rules come into force on 9 December 2019.