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This article was authored by Laven Partners, a provider of compliance, due diligence and operations services based in London.

The collapse of the financial sector in 2008, its aftermath and resulting enquires into the notoriously bad behaviour of the banking industry has seen the FCA impose fines of unprecedented size on convicted offenders. These fines were expected to ensure that institutions would pull-up their socks and abide by the rules. In some way, however, it seems that for some institutions, these fines were viewed more as a side-cost of doing business, than as an actual penalty. Bad behaviour has not gone away and the public does not feel that justice was seen to be done. The protruding theme highlighted with scandals is the lack of individual accountability.

Enter the Senior Managers Regime… A replacement of the Appointed Person's Regime (commonly accepted to be unsatisfactory by the authorities). The new regime is now assigning specific responsibilities to certain specific senior individuals in key positions throughout the banking hierarchy. This starts on March 2016… and with the political ill will that exists for alternative fund managers, it could be expanded to the asset management industry. Be aware…

This new Regime does not just offer a new name, but a host of increased responsibilities and sanctions. Unsurprisingly, the sanction that has raised most concerns is that of the possibil......................

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