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Senior Manager presence in the UK

Updated: Jul 1

In response to an increase in senior managers applications from individuals who are not based in the UK, the FCA has highlighted how important it is for their to be a UK presence commensurate with the individual's reponsibilities in the UK entity.

When speaking at TheCityUK International Conference 2024, FCA Executive Director Sarah Pritchard commented:

“If firms run or manage their UK operations from elsewhere, our ability to supervise them is lessened. As is our ability to hold parties to account should things go wrong.  It is for this reason that we expect senior managers to spend time in the UK appropriate with their responsibilities here.”

The regulator, in our experience, is always keen to see UK presence from senior management but different business models and responsibilities have led to different outcomes for our clients. The recent comments may reflect the fact that applications can expect evenmore scrutiny on location of individuals.

Blue passport against union jack flag background

Sarah Pritchard's comments very much echoes what we heard at the APCC's spring conference earlier this year when Dominic Cashman, FCA Director of Authorisation, discussed the FCA's expectations about the ‘mind and management’ of regulated firms.

We would expect that some flexibility over location remains, other than for the Money Laundering Reporting Officer, but that individuals should be expected to be questioned and firms should consider how to align responsibilities with location where a full-time UK presence is not possible.


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