FCA compliance is a working system of governance, controls, records and oversight, not a single policy document. Harper James is a modern, full-service UK commercial law firm advising ambitious businesses on the laws of England and Wales. For a regulated firm, the starting point is its regulatory perimeter, permission set and business model, followed by the FCA Handbook requirements that apply to its activities. Key areas include the Principles for Businesses, the Senior Managers and Certification Regime (SM&CR), the Systems and Controls sourcebook (SYSC), financial crime controls, conduct rules and client money requirements.
The Consumer Duty remains central to FCA supervision. Firms need evidence that their products and services deliver appropriate outcomes, offer fair value, communicate clearly and provide suitable support throughout the customer journey. Operational resilience is also a standing requirement. Firms should identify important business services, set impact tolerances, map dependencies, test disruption scenarios and record remediation. The FCA’s latest regulatory and supervisory material is a useful starting point for tracking consultations, thematic reviews, finalised guidance and enforcement priorities.
A workable framework follows a repeatable sequence. First, document the firm’s permissions, customer types, products, distribution channels and material outsourcing arrangements. Next, create a risk assessment covering conduct, financial crime, prudential matters, data, technology and third-party providers. Assign each control to an owner, define the required evidence and set a review frequency. The compliance monitoring plan should then test whether controls operate in practice, not simply whether policies exist. Findings need a recorded rating, responsible owner, deadline and escalation route.
The board or governing body should receive regular reporting on breaches, complaints, vulnerable customers, financial promotions, training, operational incidents, outsourcing and Consumer Duty outcomes. Senior managers need current Statements of Responsibilities and reasonable steps records that show how they discharged their duties. Staff training should be role-specific, supported by competence assessments and refreshed when the business or rules change. A proportionate annual review should test whether the framework still matches the firm’s permissions, risk appetite and operating model. This evidence gives the FCA a clear account of how compliance is managed, challenged and improved.