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Past Event
10 September 2009

Extension of UK Regulation to International Personnel—The Revised FSA "Approved Persons" Regime

The dynamic of relations between the UK Financial Services Authority (FSA) and senior managers of FSA authorized firms and their parent companies is undergoing major change.

On July 27, 2009 the FSA confirmed a number of changes to the scope and application of its "Approved Persons" regime, under which the holders of key positions of influence in FSA regulated firms must have individual registration and satisfy standards of competence and integrity.

Crucially, and for the first time in the UK, individuals outside an FSA authorized firm, but employed in the wider group and who have "significant influence" over the FSA authorized firm, may be subject to FSA supervision and regulation. This will apply regardless of where they are based and even if they are not employees or officers of the FSA regulated firm. Proprietary traders are also set to fall under the new regime.

At the same time the FSA is requiring ever more stringent standards of competence and reputation of director level approved persons, which is resulting in disciplinary actions and individuals being removed from their posts. Greater scrutiny of applications has also resulted in individuals and firms being encouraged to withdraw applications where the FSA considers that individuals do not meet the standards required.

These changes came into force on August 6, 2009, with a six-month transitional period to February 6, 2010. If the changes are not fully understood and taken into account in business policies and structures then risk to the business and the individuals concerned will be increased.

This teleconference will address the extensions to the regime, the implications surrounding supervision and enforcement and how institutions can best position themselves to mitigate any risk.

Please join financial services partners Angela Hayes, Nicholas Kynoch and associate Matt Baker for this 30-minute teleconference.

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