SMCR Implementation

The Senior Managers and Certifications Regime (SMCR) is effective in the U.K. from 9 December 2019, following its extension to all U.K. investment firms, and effectively replaces the Approved Persons Regime for a majority of firms.

In contrast to many FCA regulations, the impact of SMCR will be felt well beyond the compliance department, and for the senior managers who are responsible for running these firms, this is arguably the most significant new regulation of the past 15 years.

Greyline stands ready to provide comprehensive and practical support for any firm grappling with SMCR implementation. We maintain a flexible approach and can offer any combination of services – from a high-level sense check of your implementation plan all the way through to comprehensive and bespoke support in every aspect of your implementation. This may include some or all of the following, depending on your firm’s needs:

  • Undertaking an all-staff mapping exercise between the approved persons regime and SMCR to include the following:
    • Identifying senior managers, certified persons, individuals subject to the conduct rules and ancillary staff;
    • Uniquely allocating senior management functions, prescribed responsibilities and certification functions to each individual; and
    • Documenting all of the above including the analysis and rationale for each decision.
  • Drafting all required statements of responsibilities (senior managers only) and regulatory job descriptions (recommended for all staff, including certified persons).
  • Providing bespoke training to senior managers, certified persons and, if required, any other impacted staff.
  • Providing hands-on assistance with all necessary policy, procedure and template updates. This consists of a two-stage process:
    • Drafting bespoke updates to your current policies, procedures and templates to bring them into line with SMCR, as far as possible, within your existing framework; and
    • Undertaking a gap analysis and providing and tailoring new policies, procedures and templates as required to cover the new areas (e.g. certifications, regulatory references) and ensure full compliance.
  • Consultation and advice on any other issues related to SMCR and the steps required to ensure compliance.
Since our services are specifically aimed at alternative investment managers, and in this case Core Regime SMCR firms, our offering is also more streamlined and cost effective for small and medium size firms, rather than being geared (and priced) towards the largest financial institutions.

Please contact Nick Thomas, Greyline’s Head of U.K. Regulatory, at for more information.

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Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
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