The FCA does not assess governance by reading your governance manual. It assesses governance by examining how decisions are actually made and recorded, how risks actually escalate and how senior individuals are actually held to account. The gap between governance as documented and governance as practised is the gap that enforcement finds.
CORPORATE GOVERNANCE & RISK FRAMEWORKS
Good Governance Is Not What the Regulator Finds. It Is What Holds Up.
Cambitas designs governance frameworks, accountability structures and risk management systems that are built to operate — not to satisfy a checklist. Our principals have sat on both sides of these frameworks inside major UK financial institutions.
No obligation. Confidential from the first conversation.
Why Cambitas
Governance Advisory From the People Who Have Operated These Frameworks From the Inside.
Cambitas is led by principals who built and operated governance frameworks inside major UK financial institutions. They sat on risk committees, advised boards on accountability structures, managed FCA supervisory engagement and implemented SM&CR frameworks — as insiders under genuine regulatory pressure, not as external consultants reading from the handbook.
The governance frameworks that hold up under FCA scrutiny are built by people who understand what the FCA actually looks for when it reviews them — not people who have only ever read the rules. That distinction is the difference between governance that functions and governance that exists.
When you instruct Cambitas, you work directly with our principals. No associates. No delegation. The people who advise you are the people who do the work.
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Governance Framework Guide for UK Regulated Firms 2026
A practical guide to what the FCA expects, where firms fall short, and how to close the gap
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CORE GOVERNANCE FRAMEWORKS
The Foundations Every UK Regulated Firm Needs
These four services cover the governance foundations the FCA assesses first — and where the gap between documentation and practice is most often found.
1. Governance Framework Design & Implementation
The FCA examines governance not by reading governance documents — but by assessing whether those documents reflect how the firm actually operates.
What we see in practice
The most consistent finding in FCA governance reviews is not that firms lack governance documentation. It is that their documentation describes governance arrangements that do not exist in practice — committees with no meaningful oversight, risk escalation paths no one follows, accountability structures allocated on paper to individuals who have no awareness of what is attributed to them. Documentation without operational reality is the governance failure the FCA cites most often.
What we do
We design governance frameworks built around how the organisation actually operates — mapping real decision-making structures, designing oversight arrangements that function in practice, establishing board and committee mandates with clear accountability, and building the documentation that accurately reflects the governance that exists rather than describing governance that should exist.
2. SM&CR Implementation & Individual Accountability
SM&CR is the FCA's sharpest tool for holding individuals personally responsible when governance fails. Most firms underestimate how precisely it can be applied.
What we see in practice
The FCA's enforcement record since SM&CR came into full force is instructive. When governance failures occur, the FCA's first question is whether the Senior Management Function allocation accurately reflected the individual's actual responsibilities — and whether the individual understood what their function covered. Vague Statements of Responsibilities, accountability gaps between senior management functions, and individuals who cannot describe their own responsibilities under the regime are each treated as governance failures, not administrative ones.
What we do
We design SM&CR frameworks that map accountability to how the organisation actually operates — accurate SMF allocation, Statements of Responsibilities written to reflect real decision-making authority, clear lines of accountability between functions, and governance structures the FCA would recognise as genuine. We also advise on Certification Regime implementation and Conduct Rules application across the firm.
3. Enterprise Risk Management Frameworks
Risk frameworks that exist to satisfy a compliance requirement rather than to manage risk are the ones that fail when they are needed most.
What we see in practice
The three lines of defence model is widely described in UK regulated firms and inconsistently implemented. First-line risk ownership is often nominal — business units treat risk as a second-line function and escalate everything. Second-line oversight is often reactive — reviewing rather than challenging. Third-line audit is often confined to backward-looking assurance rather than forward-looking risk assessment. The FCA's supervisory visits consistently find these operational gaps behind well-documented risk frameworks.
What we do
We design enterprise risk management frameworks that operate as genuine risk management systems — clear first-line risk ownership with operational accountability, second-line oversight functions with real challenge authority, and risk escalation processes that function under time pressure. For regulated financial services firms, we design risk frameworks that satisfy both FCA supervisory expectations and the commercial operating requirements of the business.
4. Compliance Governance & Three Lines of Defence
Compliance monitoring programmes that do not test the controls they are supposed to monitor provide assurance that is indistinguishable from no assurance at all.
What we see in practice
The FCA expects compliance monitoring programmes to be risk-based — focused on the highest-risk activities, testing controls genuinely rather than confirming they exist, and producing findings that result in action. Compliance programmes that test low-risk areas to generate positive findings, that confirm documentation rather than testing operational controls, or that produce findings filed rather than addressed have the form of compliance oversight without the substance. The FCA has been explicit about this in multiple supervisory letters.
What we do
We design compliance governance frameworks and monitoring programmes that provide genuine oversight — risk-based monitoring plans, testing methodologies that assess whether controls work rather than whether they exist, escalation processes for compliance findings, and board reporting that gives directors an accurate picture of the firm's compliance position. For firms subject to FCA supervision, we design programmes aligned with the FCA's current supervisory priorities.
SPECIALIST GOVERNANCE AREAS
Conduct Risk, Board Governance & the FCA's Highest Priorities
The areas below represent the FCA's most active supervisory and enforcement focus in governance for UK regulated firms.
5. Conduct Risk & Market Abuse Governance
Conduct risk governance is one of the FCA's most active supervisory priorities — and one of the areas where the gap between documented frameworks and operational reality is widest.
What we see in practice
The FCA's conduct risk supervision focuses on three questions: does the firm understand the conduct risks its business model creates, does it have controls proportionate to those risks, and do those controls demonstrably work? Firms with conduct risk frameworks built around generic risk categories rather than their specific business model, or with surveillance programmes designed to avoid generating findings rather than to detect them, are exposed when the FCA looks closely.
What we do
We design conduct risk frameworks specific to the firm's business model — identifying the conduct risks that actually exist, designing controls proportionate to those risks, building surveillance and monitoring programmes that detect problems rather than confirm everything is fine, and advising on the governance arrangements that satisfy the FCA's expectation of genuine conduct risk ownership at senior management level.
6. Board & Committee Governance Structures
Board governance in regulated firms carries obligations that boards in unregulated businesses do not face — and the FCA holds boards to a higher standard of active oversight than most appreciate.
What we see in practice
The FCA expects regulated firm boards to demonstrate active, informed oversight of the regulatory risks the firm carries — not passive receipt of management information. Board minutes that record decisions but not the challenges, discussions and dissent that preceded them are treated as evidence of inadequate governance. Non-executive directors who cannot demonstrate engagement with the firm's risk framework are a governance concern in their own right. The FCA has pursued individual board members on this basis.
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What we do
We design board governance structures, committee mandates and operating models for regulated firms — covering board composition, committee architecture, information flows from management to board, board reporting frameworks and the oversight processes that demonstrate genuine engagement with regulatory and conduct risk. We advise on the governance arrangements that new and existing regulated firms need to satisfy FCA supervisory expectations at board level.
FURTHER GOVERNANCE SERVICES
Six More Areas We Cover
Each service below addresses a specific governance obligation. Each links to a dedicated advisory page.
7. Governance for New Products & Regulatory Permissions
The FCA expects firms adding new products, business lines or regulatory permissions to demonstrate that governance arrangements have been updated to reflect the new activities before they commence. New product governance — the framework for assessing, approving and monitoring new products from a conduct risk perspective — is one of the areas the FCA focuses on most acutely in Consumer Duty supervision. We design product governance frameworks and advise on governance arrangements for new activities and permission variations.
8. Outsourcing & Operational Resilience Governance
The FCA's operational resilience framework requires firms to identify their important business services, set impact tolerances and demonstrate they can remain within those tolerances during severe but plausible disruptions. For firms relying on third-party outsourcing arrangements for critical services, this means governance of those arrangements must satisfy the FCA's standards — which most existing outsourcing governance frameworks do not. We design outsourcing governance and operational resilience frameworks aligned with current FCA expectations.
9. AI & Technology Risk Governance
UK financial services firms deploying AI face governance expectations from the FCA that most have not assessed. The FCA has signalled that AI tools used in regulated activities — credit decisions, fraud detection, customer communications, trading — should be governed with the same rigour as any other material business process. Model risk governance, explainability requirements, human oversight mechanisms and accountability structures for AI outcomes are all areas the FCA has flagged as supervisory priorities recently. We design AI and technology risk governance frameworks for regulated financial services firms.
10. Governance Reviews, Gap Analysis & Remediation
For firms that have received FCA supervisory feedback on governance quality, or that want to understand their current position before a supervisory review, a structured governance gap analysis provides a clear picture of where frameworks need strengthening. We conduct governance reviews assessing current arrangements against FCA expectations, produce gap analyses identifying priority areas, and design remediation programmes with clear timelines and accountability. For firms in active regulatory engagement, we advise on governance remediation that demonstrates genuine improvement to the FCA.
11. Governance Training & Board Advisory Support
Governance training for boards and senior managers in regulated firms must go beyond describing the rules — it must equip individuals to exercise the oversight and accountability the FCA expects of them. We provide governance training programmes for boards, senior managers and risk and compliance teams — covering the FCA's governance expectations, SM&CR obligations, individual accountability and the conduct risk frameworks the firm operates. Training is tailored to the firm's specific context and regulatory position, not delivered from a generic template.
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12. Governance for Digital Asset & Fintech Businesses
Fintech and digital asset businesses seeking FCA authorisation must demonstrate governance frameworks that satisfy the FCA's standards from day one — not as a post-authorisation project. The governance requirements for cryptoasset businesses under the new FCA regime are demanding: board accountability structures, risk oversight frameworks, SM&CR implementation and compliance governance must all be in place before an application is submitted. For UAE-based businesses seeking FCA authorisation alongside VARA or ADGM frameworks, governance arrangements must satisfy both regulators' requirements. We design governance frameworks for fintech and digital asset businesses at every stage.
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"The FCA is not fooled by governance that looks right on paper. It looks past the documents to what actually happens in the firm — and what it finds there shapes its entire assessment."
Cambitas — from direct FCA supervisory engagement on behalf of UK regulated clients
WHAT THE FCA LOOKS FOR
Three Governance Questions the FCA Asks in Every Review
These are the three questions that structure every FCA governance assessment — in supervisory visits, skilled person reviews and enforcement investigations.
Are decisions actually made here?
The FCA assesses whether governance bodies — boards, risk committees, audit committees — exercise genuine oversight or act as passive recipients of management information.
Does risk actually
escalate?
Does material risk reach the right people through the escalation process, or does it get managed down before reaching governance bodies? The FCA tests whether escalation paths function under pressure.
Is anyone actually accountable?
When something goes wrong, can the FCA identify a named individual whose function covered the area of failure? Governance gaps are accountability gaps — and SM&CR makes accountability personal.
HOW WE BUILD IT
Building a Governance Framework the FCA Would Recognise as Genuine
This is the sequence Cambitas follows when designing a governance framework for a UK regulated firm. The goal at each step is operational function — not documentation production.
Map How the Firm Actually Operates
Before designing governance, understand what decisions are actually made, by whom, on what basis, and through what processes in the firm as it currently functions.
Most governance failures begin with frameworks designed around an idealised organisational structure rather than the actual one. Governance built on accurate operational mapping functions. Governance built on how things should work does not.
Allocate SM&CR Functions Accurately
Allocate Senior Management Functions to the individuals who genuinely hold the responsibilities those functions describe — not to individuals for whom the function is an administrative attribution.
The FCA will scrutinise whether SMF allocations accurately reflect operational reality. If an individual's Statement of Responsibilities attributes decision-making authority they do not exercise, that misalignment is a governance failure waiting to be found.
Design Governance Bodies That Function
Establish board and committee structures, mandates and operating models that create genuine oversight — clear terms of reference, appropriate information flows, challenge processes that work under commercial pressure.
A governance body whose minutes record unanimous agreement on every material issue is a governance body the FCA will treat as inadequate. Real governance involves documented challenge, dissent and accountability.
Build Risk Escalation That Works Under Pressure
Design risk escalation pathways that function when they are most needed — under commercial pressure, time constraints and management incentives to manage risk down rather than up.
Escalation processes designed for normal operating conditions fail at exactly the moments governance is most critical. The test of an escalation framework is whether it functions when the firm would prefer it did not.
Implement Compliance Oversight With Real Teeth
Design a compliance monitoring programme that tests whether controls actually work — not whether they exist, not whether documentation describes them correctly, but whether they function as intended in practice.
The FCA's compliance programme expectations are risk-based and outcomes-focused. A compliance programme that generates consistently positive findings without examining controls in depth provides assurance that is indistinguishable from no assurance at all.
Test, Document and Maintain
Run governance effectiveness reviews, update documentation when structures change, and treat governance as a live operational system rather than a project that is complete when documentation is filed.
Governance frameworks that are not regularly reviewed and updated become inaccurate over time. The FCA expects governance to reflect the firm as it currently operates — not as it operated when the framework was last reviewed.
A NOTE ON GOVERNANCE AND FCA AUTHORISATION
For firms seeking FCA authorisation, governance frameworks must be operational before the application is submitted — not described as a post-authorisation project. The FCA expects to see a functioning governance framework in the application, not a plan for one. Applications that treat governance as something to be built after authorisation consistently face extended review periods.
GO DEEPER
Explore Our Governance Advisory Guides
Each page below provides detailed practical guidance on a specific governance area — what the FCA expects, what good practice looks like and what to do when the current position falls short.
SM&CR Implementation
How to build SM&CR frameworks that accurately reflect operational reality, protect individuals and satisfy FCA scrutiny - including Statements of Responsibilities and Certification Regime design.
Compliance Monitoring Design
What a risk-based compliance monitoring programme looks like in practice - how to test controls rather than confirm documentation, and how to produce findings the board can act on.
Governance Reviews & Remediation
How Cambitas conducts a governance gap analysis - what is assessed, what good governance looks like against FCA standards, and how remediation programmes are structured and delivered.
THE DISTINCTION THAT MATTERS
Governance on Paper vs Governance in Practice
The FCA is not assessing whether you have governance documentation. It is assessing whether your governance operates as described. Here is what that distinction looks like across the areas it examines most closely.
| Area | Governance on Paper | Governance in Practice |
|---|---|---|
| Board oversight | Board minutes record challenge and decisions reached. Information packs distributed before meetings. Non-executives present at all meetings. | Minutes document the challenge and discussion that preceded each decision. Non-executives demonstrably engaged. Board information packs contain what directors need to exercise oversight — not what management wants them to receive. |
| Risk escalation | Risk escalation policy documented. Three lines of defence described. Risk committee meets quarterly. | Material risks reach the risk committee in time to influence decisions. First-line managers escalate rather than resolve. Risk committee challenges management positions rather than endorsing them. |
| SM&CR allocation | All SMFs allocated. Statements of Responsibilities signed. Responsibilities Map completed and filed. | SMF allocations match who actually makes the decisions described. Individuals know what their function covers. Responsibilities Maps are updated when roles change. |
| Compliance monitoring | Compliance monitoring plan in place. Monthly monitoring reports produced. Compliance findings reported to board. | Monitoring plan is risk-based and focuses on highest-risk activities. Testing assesses whether controls work, not whether documentation exists. Findings lead to action, not filing. |
| Conduct risk | Conduct risk framework documented. Conduct risk appetite statement approved. Conduct risk training completed annually. | Conduct risk framework reflects the firm's specific business model. Controls are proportionate to actual conduct risks. Surveillance detects problems rather than generating clean-looking outputs. |
| Governance review | Annual governance effectiveness review conducted. Report produced. Board confirms governance is effective. | Governance review examines whether frameworks function operationally — tests escalation, challenges documentation accuracy, assesses whether accountability is real. Board receives an honest assessment. |
→ WHICH COLUMN DESCRIBES YOUR FIRM?
If any row in the middle column accurately describes your current governance position, that is the starting point for a productive conversation with Cambitas.
WARNING SIGNS
Three Signs Your Governance Framework Needs Attention
These are the three patterns most consistently found in UK regulated firms that subsequently face FCA supervisory concerns or enforcement action on governance grounds.
Board Minutes Show No Challenge or Dissent
Every board and committee decision is recorded as unanimous. The minutes document conclusions — not the challenge, discussion or disagreement that should precede them.
Risk Is Managed Down Not Up
Material issues are resolved at business unit level before reaching the risk committee. Senior management learns about problems after they have become crises rather than before.
SMF Holders Cannot Describe Their Function
Individuals holding named Senior Management Functions cannot accurately describe what decisions fall within their function or what they would be held accountable for if something went wrong.
→ RECOGNISE ANY OF THESE?
All three are addressable with the right advisory support before the FCA conducts a supervisory review. After the review, remediation is more expensive and happens under regulatory scrutiny.
WHO WE WORK WITH
The Organisations We Advise on Governance
Governance advisory for UK regulated firms covers a wide range of organisations — from those building governance frameworks from scratch through to firms remediating under regulatory pressure.
| UK Regulated Financial Services Firms |
|---|
| Investment firms, asset managers, broker-dealers, payment institutions and banks navigating FCA governance expectations, SM&CR obligations and the ongoing requirement to demonstrate operational governance that satisfies supervisory scrutiny. |
| UK Fintech & Digital Asset Businesses |
|---|
| Fintech and digital asset businesses seeking FCA authorisation or managing growing regulatory obligations — where governance frameworks must be operational before authorisation applications are submitted and must satisfy FCA standards from day one. |
| UK Boards & Senior Management Teams |
|---|
| Directors, non-executive directors and Senior Management Function holders who carry personal accountability under SM&CR and need governance structures that genuinely protect them — not frameworks that attribute responsibility without the support to exercise it. |
| UK Firms Under FCA Supervisory Review |
|---|
| Firms that have received FCA supervisory feedback on governance quality, skilled person review findings or enforcement concerns — where governance remediation must demonstrate genuine improvement to the regulator within defined timescales. |
| International Firms Entering the UK Market |
|---|
| UAE-based and other international firms seeking FCA authorisation for UK regulated activities — where governance frameworks must meet FCA standards as a precondition of authorisation. We advise on governance design for overseas firms throughout the authorisation process. |
| PE-Backed & Institutional Investors in Regulated Firms |
|---|
| Private equity and institutional investors acquiring or holding regulated financial services businesses — where governance quality directly affects regulatory risk, transaction value and the firm's ability to operate and grow without supervisory constraint. |
SITUATIONS WE WORK THROUGH
Questions We Are Asked Every Week
Direct answers to governance and risk framework questions that UK regulated firms bring to us most often.
"The FCA has raised concerns about our governance in a supervisory review"
Supervisory feedback on governance requires a structured response — not defensive reassurance that existing frameworks are adequate. The FCA expects to see a specific gap analysis, a credible remediation plan with clear timelines and evidence of genuine engagement with the concerns raised. Responses that explain why the current governance is better than the FCA thinks, without addressing the specific concerns identified, consistently produce worse outcomes than responses that acknowledge the gap and commit to addressing it.
"We need to update our SM&CR framework but don't know where the gaps are"
The most common SM&CR gaps are: SMF allocations that do not match who actually holds the decision-making authority described in the function, Statements of Responsibilities that have not been updated when roles changed, accountability gaps between adjacent Senior Management Functions, and individuals who have not been adequately briefed on what their function covers. A structured SM&CR gap analysis identifies which of these apply and produces a prioritised remediation plan.
"Our board governance feels like a process rather than genuine oversight"
Board governance that functions as process rather than oversight has a characteristic pattern: papers arrive too late for genuine consideration, presentations are designed to reassure rather than inform, challenge is discouraged by implicit signals from management, and minutes record conclusions without the deliberation that produced them. Genuine board oversight requires information architecture that enables challenge, a culture where dissent is documented rather than smoothed over, and non-executive directors who have sufficient knowledge of the business to ask the right questions.
"We are building a governance framework for FCA authorisation — what does the FCA actually require?"
The FCA requires a governance framework that is operational at the point of application — not a framework described as something to be built after authorisation. Specifically: SM&CR function allocations mapped to proposed senior managers with accurate Statements of Responsibilities, a board or equivalent governance body with documented oversight authority, a risk management framework that reflects the risks of the proposed regulated activities, and a compliance function with a monitoring programme designed to test those risks. Generic governance frameworks copied from templates consistently fail FCA scrutiny.
"We have a compliance monitoring programme but it never finds anything significant"
A compliance monitoring programme that consistently produces clean outputs without finding significant issues is almost certainly testing the wrong things. Risk-based compliance monitoring focuses on the highest-risk activities and tests whether controls work — not whether documentation describes them. A monitoring programme that assesses documentation rather than operational controls, or that focuses on low-risk areas to generate positive findings, provides the appearance of compliance oversight without the substance. The FCA has been explicit about this distinction in multiple Dear CEO letters.
"We are a UAE-based firm seeking FCA authorisation — what governance standards apply?"
UK FCA authorisation requires governance arrangements that meet FCA standards — regardless of the governance framework the firm operates under in the UAE. UAE VARA, ADGM and DIFC governance frameworks do not satisfy FCA governance requirements. An overseas applicant must demonstrate: a UK-appropriate SM&CR framework for the proposed regulated activities, a board or governance body with adequate oversight authority over the UK operations, a compliance function capable of meeting FCA supervisory expectations and risk management arrangements proportionate to the UK regulated activities proposed.
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FREQUENTLY ASKED QUESTIONS
Direct Answers to the Questions We Hear Most
Direct answers to UK governance and risk framework questions — focused on what the FCA actually expects and what good practice looks like.
Q1. What does the FCA expect from governance frameworks in UK regulated firms?
The FCA expects governance to be operational — not documented. This means boards that exercise genuine oversight (not passive receipt of management information), risk escalation processes that function under commercial pressure, SM&CR accountability allocations that accurately reflect who holds decision-making authority, and compliance monitoring programmes that test whether controls work rather than confirming they exist. The FCA assesses governance quality through supervisory visits, skilled person reviews and, in serious cases, enforcement investigations. The standard is whether governance actually manages the risks the firm creates.
Q2. What is SM&CR and what does it require regulated firms to do?
The Senior Managers and Certification Regime places individual accountability at the centre of governance in FCA-regulated firms. It requires firms to allocate named Senior Management Functions to specific individuals, document their responsibilities in Statements of Responsibilities, and certify that relevant staff are fit and proper. When governance failures occur, the FCA investigates whether SM&CR accurately allocated accountability — and where it did, it holds the named individual responsible. Getting SM&CR allocation right is protection for individuals and firms. Getting it wrong creates personal liability for governance failures that might otherwise be treated as firm-level issues.
Q3. What is the three lines of defence model and does the FCA require it?
The three lines of defence is the governance model most UK regulated firms operate — first line (business functions owning risk), second line (risk and compliance functions overseeing first line), third line (internal audit providing independent assurance). The FCA does not mandate this specific structure but expects regulated firms to demonstrate equivalent operational governance. Where firms describe the three lines of defence in their governance documentation but do not operate it in practice — the most common pattern — the FCA treats the gap as a governance failure rather than a structural choice.
Q4. What does a governance gap analysis involve?
A governance gap analysis assesses current governance arrangements against FCA expectations — examining whether governance bodies exercise genuine oversight, whether SM&CR allocations match operational reality, whether risk escalation functions under pressure, whether compliance monitoring is risk-based and effective, and whether board information enables genuine challenge. The output is a gap analysis identifying priority areas and a remediation plan with specific actions, accountability and timelines. For firms under FCA scrutiny, the gap analysis also informs the firm’s response to the regulator.
Q5. What governance does the FCA require for FCA authorisation applications?
The FCA requires governance frameworks to be operational at the point of application — not described as post-authorisation projects. Applications must demonstrate: SM&CR allocations mapped to proposed senior individuals with accurate Statements of Responsibilities, a governance body with genuine oversight authority, a risk framework proportionate to the proposed regulated activities and a compliance function with a monitoring programme designed to test those risks. Applications that describe governance in aspirational rather than operational terms consistently face extended FCA review periods.
Q6. Does good governance help with investor due diligence and banking relationships?
Yes — significantly. Institutional investors conducting due diligence on regulated financial services businesses assess governance quality as a direct indicator of regulatory risk and operational stability. Firms with demonstrably effective governance — operational SM&CR frameworks, functioning risk and compliance oversight, board structures with genuine challenge capability — attract better terms, faster processes and fewer conditions than firms where governance gaps are identified during due diligence. Banking partners for regulated businesses similarly assess governance quality before extending relationships. The FCA’s own guidance makes clear it considers governance quality a leading indicator of future compliance performance.
FREE DOWNLOAD
Governance Framework Guide for UK Regulated Firms 2026
Still assessing your governance position? Download our free guide first.
No obligation. No sales call unless you ask for one.
Governance that functions is a competitive advantage. Governance that exists on paper is a liability waiting to be found.
The FCA finds the gap between governance as documented and governance as practised in every supervisory visit it conducts. The firms that emerge from those visits with their regulatory standing intact are the ones that closed that gap before the regulator arrived.
Cambitas designs and implements governance frameworks for UK regulated firms — built to operate, built to satisfy FCA scrutiny and built to protect the individuals who carry accountability within them.
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