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RegulationsJanuary 4 2016

Three lines of defence rebuilt for cyber threat

The UK's Senior Managers Regime seeks to formalise responsibility for risk, yet the threat of cyber attack sits outside of traditional risk governance standards, and means that protecting against such attacks will require a rethink of the traditional 'three lines of defence' model.
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“A lack of personal responsibility has been commonplace throughout the industry,” said UK MP Andrew Tyrie, who is the chairman of the UK's Parliamentary Commission on Banking Standards, upon release of the commission’s report ‘Changing Banking for Good’ in June 2013. “Senior figures have continued to shelter behind an accountability firewall,” he added.

Individual and collective responsibility at senior management and board level is being codified to address this ‘lack’. On March 7, 2016, the Senior Managers Regime (SMR) will come into effect in the UK. It will ask that banks, building societies, credit unions and certain firms designated by the Prudential Regulatory Authority (PRA) – typically large investment banks and branches of foreign banks – are able to identify who specifically is responsible for areas of the business, with written responsibilities and a map put in place to formally link these up.

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