“With great power comes great responsibility. Yes; but in the era of SMCR, heads of compliance have found out that even a medium amount of power now comes with an almost unpalatable amount of personal accountability – and legal jeopardy.”
In his latest article, published yesterday on International Investment and Global Investor Group’s FOW, IQ-EQ’s Executive Chairman of Compliance Consulting Andrew Shrimpton highlights the global impact of the upcoming Senior Managers and Certification Regime (SMCR).
Rather than being another “London-based spectator sport”, rules of responsibility will apply equally to foreign-domiciled compliance managers with a UK office, team and infrastructure as they do to firms founded and solely based in Britain. Which means that if the London office makes a mistake, you can still be held accountable, fined or worse, even if you're based in New York, Boston or San Francisco.
All of this puts current international heads of compliance in an interesting position. Accept responsibility they can't realistically adopt (or don't want to) - or hand over the head of compliance title to someone who will, or who feels they can.