The Compliance Oversight function (SMF16) holds overall accountability for ensuring the firm’s activities comply with FCA rules, including Conduct of Business (COBS), SYSC, MAR, MLR 2017, and the Consumer Duty.The role provides independent challenge, sets the compliance framework, and ensures risks associated with CFDs, leveraged trading, cryptoassets, and other retail investment products are identified, monitored, and controlled.
Core Responsibilities
- Regulatory Framework — Maintain and oversee the firm’s compliance policies, procedures, and monitoring programme across all product lines (CFDs, FX, equities, commodities, crypto).
- CFD Oversight — Ensure adherence to FCA rules on leverage limits, appropriateness testing, negative balance protection, and marketing restrictions.
- Crypto Compliance — Oversee compliance with FCA cryptoasset financial promotions regime, AML/CTF obligations, and ensure risk disclosures meet regulatory expectations.
- Consumer Duty — Ensure products, communications, and client journeys deliver good outcomes for retail clients.
- Governance — Chair or participate in Compliance, Risk, and Product Governance Committees; provide MI to the Board.
- Monitoring & Surveillance — Oversee trade surveillance, best execution monitoring, conflicts of interest, and market abuse controls.
- Training & Competence — Ensure staff meet competency standards and receive ongoing compliance training.
- Regulatory Engagement — Act as primary contact for FCA supervisory engagement, thematic reviews, and information requests.
- Incident Management — Lead investigations into breaches, complaints, operational incidents, and ensure timely reporting (e.g., REP008, SM&CR notifications).
- Financial Crime — Oversee AML/CTF systems, sanctions screening, transaction monitoring, and suspicious activity reporting.
- Marketing & Promotions — Approve or oversee approval of all financial promotions, ensuring clarity, fairness, and compliance with FCA rules for high‑risk investments.