Has the SMCR created a new ‘accountability firewall’? [talking point]
MAY 30, 2019
Senior figures have continued to shelter behind an accountability firewall” 1. The Financial Conduct Authority’s (FCA) test of ‘personal culpability’ is the linkage between the two, while non-deliberate acts and omissions are judged against what is deemed to be ‘reasonable’ on the facts of a particular case. The post Has the SMCR created a new ‘accountability firewall’?