The December 9th deadline for SMCR is fast approaching and firms are focused on putting all the necessary legal and HR documentation in place for that date.
December 9th is Day 1 for Senior Management under the new regulations, so what happens on Day 2?
This is where the real work begins. The key challenges for Day 2 for all organisations will be:
– How as a senior Manager can you demonstrate you have taken all reasonable steps to control the business effectively on an ongoing basis?
– How as the Senior Manager or even more so, the SMF4 can you be assured that breaches to regulations are appropriately prevented within the business on an ongoing basis?
– How do you ensure that the appropriate culture is in place and embedded within the business operations, and employee’s performance of their role on an ongoing basis?
Day 2 and onwards is going to be particularly difficult for any organisation which does not have a clear view and understanding of all the potential risks of regulatory breaches that exist within their business processes, the controls they have in place to mitigate, and whether those controls are effective. This includes all processes, including those that are outsourced to third parties.
A robust Governance Framework sitting over the risk and compliance management of the processes within the organisation is essential to both enable and demonstrate that Senior Management are fulfilling their responsibilities under SM&CR.
Who is ready for DAY 2?
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