Mark Steward @ FCA makes four practical observations about the Senior Manager’s Regime. First, the duty of responsibility does not create a separate and independent basis for senior management liability. A senior manager’s liability, under the duty of responsibility, depends on the firm’s wrongdoing because it is, in essence, a duty to act reasonably as a […]

The expanding scope of individual accountability for corporate misconduct – speech by Mark Steward (FCA) Mark Steward, director of enforcement and market oversight, FCA, has given a speech on the accountability of senior managers for corporate misconduct at the New York University program on corporate compliance and enforcement. Mr Steward explained that the FCA’s senior […]