01
Personal liability is real
Under SM&CR, Senior Managers carry individual accountability regardless of firm size or stage. Most boards have not stress-tested what they would say if the FCA asked them to demonstrate their oversight.
Regulatory Advisory · Financial Services
Board-level clarity.
Independent of management.
NJW Consulting advises boards and senior leadership teams at UK financial services firms — helping them understand what they are genuinely responsible for, challenge management effectively, and demonstrate credible oversight to the FCA.
The regulatory landscape
100+
Live FCA, PRA and Bank of England regulatory initiatives across UK financial services
Day 1
SM&CR personal accountability applies from first day of FCA authorisation — regardless of firm size
2026
FRC Provision 29 now requires boards to evidence internal control frameworks with outcome-based statements
The challenge
Boards are accountable.
But they depend on management to interpret risk.
The regulatory framework places personal liability squarely on board members — yet most boards receive their regulatory view solely through the compliance function. That is a structural gap that the FCA increasingly expects firms to address.
02
Management filters the view
Compliance functions report into management, not the board. The board rarely receives an independent assessment of the firm's regulatory position — or of the adequacy of management's own frameworks.
03
AI governance is undefined
FCA expectations on AI governance and model risk are evolving rapidly. Most boards do not yet have a clear picture of what adequate oversight means — or where their personal exposure sits.
What we do
Three focus areas.
One independent adviser.
FCA Conduct & Consumer Duty
Board ownership of Consumer Duty outcomes. Independent oversight of management frameworks. Preparation for FCA scrutiny and regulatory review.
Conduct RiskPrudential Requirements
Internal control frameworks and FRC Provision 29 compliance. Capital and liquidity governance. Board-level challenge of risk appetite and management reporting.
Prudential RiskAI Governance & Model Risk
Board accountability for algorithmic decisions. FCA expectations on AI explainability. Personal liability under SM&CR for AI-related failures and model risk oversight.
AI Governance“The initial diagnostic session is without charge — because the right starting point is understanding your board's specific exposure, not assuming it.”
Arrange a Diagnostic Session