SM&CR is designed to reduce harm to consumers and strengthen market integrity by improving culture, governance and accountability.

The regime focuses accountability on a narrower number of individuals at the top of the firm, encourages individuals to take greater responsibility for their actions, and makes it easier for firms and regulators to hold individuals to account.

Applying on a legal-entity basis, SM&CR affects senior managers, board members and certification staff who have significant ability to cause significant harm to a firms business.

Implementation is not only a documentation exercise. Firms need clear responsibilities, evidence of reasonable steps, fit-and-proper certification, and governance that works in practice. GRTs subject-matter experts help firms interpret and implement SM&CR and benchmark against industry practice.