FCA has published its policy statement to accompany its final rules on how it will bring enforcement action against individuals under the SMR (see above for the final rules). The paper elaborates on when FCA will use its own-initiative powers to vary a Senior Manager’s approval, but declined to give further guidance on how it will use its powers proportionately as it says this will depend on the particular circumstances. It notes how the law will require it to use its powers transparently. FCA has also confirmed it will carry on with its current approach to requiring attestations at the moment, but will keep this under review. (Source: FCA Publishes SMR Enforcement Changes)