Compliance, Culture and Evolving Regulatory Expectations

May 2021


In his speech to the NYU Law School, Mark Steward, FCA Executive Director of Enforcement and Market Oversight explained how the SM&CR has evolved and how the FCA has been developing a new tool, the 5 conduct questions or 5CQ, expressly to help firms implement more effective change programmes as well as helping the FCA to interrogate progress:

The most recent report on progress, using the 5CQ, reflected some new conduct risks triggered by the pandemic. The report also contained an assessment of both an improving recognition of conduct risk among firms and as well as recording significant gaps and areas of improvement.


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