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The term reasonable steps is used in the first three SMF Conduct Rules:
But what does the term ‘reasonable steps’ imply?
The Culpability Standard:
The regulator has stated that “A person will only be in breach of any of the rules in COCON where they are personally culpable.
Personal culpability arises where:
This workshop aims to unravel the confusion that lies around this terminology and shed light on the regulator’s expectations.
This workshop is also available as an in-house programme, which means you can tailor it to exactly what you and your colleagues require. Pricing for in-house will depend on what is required. Enquire about this option by contacting our training team.
Regulatory requirements
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With over 20 years training experience in financial services, Stephen is well placed to support you across a range of consultancy and developmental ac...
With over 20 years training experience in financial services, Stephen is well placed to support you across a range of consultancy and developmental activities. He is a former Head of Education for HSBC covering the UK and Europe, responsible for regulatory and financial crime related compliance learning, and has first-hand experience of meeting logistical deadlines complicated by volume, complexity and geography. His time at HSBC was during intense scrutiny from regulators and government functions during the bank’s Deferred Prosecution Agreement.
With other roles ranging from advising customers within a high-street retail branch, to Senior Vice President responsible for Global Risk & Compliance training at a US-based bank, Stephen’s range of experience is adaptable to your business. He also worked in the Insurance Firms division at the Financial Conduct Authority (in the FSA days) where he was the divisional expert for the rules and outcomes required under the Training & Competence handbook. Stephen won the Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm” in 2010.
The HSBC role, along with five years at Barclays in their Private Clients and Wealth functions, has seen Stephen work with retail, commercial, wholesale and private banking channels. While enjoying the design and delivery of training to an audience either live or virtually, Stephen can also work with your compliance, HR and operational teams to build or enhance your learning framework, ensuring appropriate systems, controls, checks and balances are in place to withstand any robust regulatory scrutiny, as well as delivering sustainable commercial benefits to your business.
This workshop is aimed at senior managers operating in foreign banks in the UK, and those who are preparing for appointment to these roles.
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