5/13/2021 12:56:10 PM | less than a minute read

SMCR Reasonable steps - simple in theory, challenging in practice

Get in touch

Elizabeth Dowd

Financial Regulation Partner, London

Get in touch

Elizabeth Dowd

Financial Regulation Partner, London

'Reasonable steps' has now become a part of the vocabulary of the regulators and senior managers alike. But what may appear to be a relatively simple concept can be extremely challenging in practice - both in terms of a senior manager establishing a 'reasonable steps' framework and in demonstrating that a senior manager took reasonable steps when things may go wrong.

To read more about 'reasonable steps' and how you evidence them see our latest Risk Advisory blog post here.

As highlighted in a recent speech by Mark Steward (Director of Enforcement and Market Oversight): “implementing the [senior managers regime] has meant firms have built into their systems explicit reasonable steps to prevent non-compliance. This has required an assessment of what may make a particular control system or function more vulnerable to failure because it is in those places that the senior manager’s reasonable steps need to be particularly evident.”

www.linklaters.com/...