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Consultation on JFSC definition of “senior management functions”


On 29 April 2022, revised legislation came into force that widened the scope of JFSC civil financial penalties regime.

The revised legislation will give JFSC the power to impose a civil financial penalty on an individual in a regulated business who performs a “senior management function”. A financial penalty will be able to be imposed if they were culpable in a significant and material contravention by the business of either the Money Laundering Order or one of our Codes of Practice.

Purpose of consultation

JFSC are looking for feedback on proposed notice that will define “senior management functions”. The notice will determine which senior managers in a regulated business will fall within the scope of the civil financial penalties regime.

To assist trade associations in explaining the consultation proposals to their members and to facilitate feedback to JFSC, the JFSC will be holding a briefing for representatives of those associations during the consultation period. Invites will be sent out shortly.

Impact of consultation

JFSC proposed notice has the potential to affect senior managers working in the finance industry and those working in ‘designated non-financial businesses and professions” - such as estate agents, lawyers, accountants, high value dealers and casinos.

Read our consultation and respond

The closing date for responses to JFSC consultation is Friday 29 July 2022.