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Senior Management Arrangements, Systems & Controls (SYSC)

7.1 Introduction

SYSC (Senior Management Arrangements, Systems & Controls) details the FCA’s requirements for firms to have effective and appropriate systems and controls in place to ensure compliance with regulatory requirements and mitigation against risk.

This compliance manual contains many of those controls in the form of policies, procedures and guidance information and provides specific Risk Management procedures and measures for mitigating against and managing both internal and external risk factors.

SYSC also encourages the company Director/s and Senior Managers to take responsibility for ensuring that the relevant systems and controls are developed, implemented, monitored and maintained to comply with regulatory requirements and business expectations.

Whilst not directly accountable for the development and implementation of compliant procedures, systems and controls, all staff are expected to read and understand the controls in place to guarantee regulatory requirements are met and to comply with the rules; in addition to taking responsibility for any procedure or governing guidance that relates to their own job role or business area.

Compliance applies to everyone and is a foundation on which this firm has been built and it is a contractual expectation and requirement that you comply with the rules, requirements and procedures at all times.

7.2 General Organisational Requirements

Within the company, significant responsibilities have been given to key staff, to ensure that the oversight of each designated compliance aspect or business activity is monitored. The staff and responsibility they have been assigned are detailed below and more information regarding the Approved Persons and Controlled Functions can be read in the relevant sections/s of this manual.

Area of Responsibility Assigned to Position
e.g. Money Laundering Officer e.g. Bob Smith e.g. Senior Manager
e.g. Operational Procedures e.g. Jane Jones e.g. Director
e.g. Compliance Oversight e.g. Jim Davies e.g. Compliance Manager
e.g. Health & Safety    
e.g. IT & Risk Management    
e.g. Complaint Handling    

This record is kept up-to-date and overall responsibility for the monitoring and oversight of this record is with [Compliance Officer].

The General Requirements as defined the SYSC 4 of the FCA Handbook have been addressed in differing sections of this manual, a reference to each location is therefore provided below for ease of use.

[Once you have customised this compliance manual and added/removed any sections specific to your business type, you can note below where each general requirement is located in the manual for ease of reference.]

General Requirements (SYSC 4) Compliance Manual Section
Organisational Chart
Apportioning of Responsibilities
Regular Monitoring
Confidentiality of Information
Business Continuity
Risk Management
Internal Reporting
Administrative Procedures
Accounting Procedures