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FCA Consumer Duty Update: Assessing Fair Value

The FCA has published the findings from its review of firms’ fair value assessment frameworks and set out implementation priorities for firms. On 10 May 2023, the FCA published a speech by Sheldon Mills, FCA Executive...more

FCA Issues Final Notice to Former Banking CEO Over Anti-Money Laundering Failures

The case provides instructive practical examples of the “reasonable steps” companies can take according to the FCA and a reminder of the FCA’s cultural expectations of CEOs. On 16 November 2022, the FCA issued a final...more

US DOJ Emphasises Importance of Corporate Culture

UK companies should be aware of the increasing focus on corporate culture by regulators on both sides of the Atlantic. In a recent speech that has garnered significant attention, US Deputy Attorney General Lisa Monaco...more

Organisational Culture and Conduct - The role and expectations of bystander employees: the missing piece of the puzzle?

This article explores whether culture-oriented organisations may be missing an important trick by effectively overlooking the potential real-time interventional role of employees who observe a colleague’s inappropriate...more

Prioritizing Corporate Culture: Lessons for Companies from the Major League Baseball Sign-Stealing Investigation

The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...more

FCA Warns of ‘Significant Weaknesses’ in Firms’ Implementation of the Conduct Rules

All firms should take note of the FCA’s latest feedback on SMCR implementation. In its latest piece of feedback on firms’ implementation of the SMCR, the FCA indicated that firms must improve their implementation of the...more

Transforming Culture in Financial Services - The FCA Renews Its Approach

New FCA Discussion Paper demonstrates how the regulator’s thinking in relation to culture has evolved. Introduction - In Discussion Paper (DP) 18/2, the FCA has taken an unusual approach to a topic that has received...more

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