AFB Seminar: Managing Conduct Issues for Visitors to the UK from Head Office and Affiliates

The Senior Managers and Certification Regime (SMCR) places accountability obligations on UK regulated firms. For UK subsidiaries and branches of non-UK headquartered banks, however, one of its most practically complex dimensions is the treatment of visitors from overseas parent institutions and affiliated entities. Group governance structures typically place authority at the parent level, whilst SMCR places regulatory accountability at the UK entity level. The result is that visiting personnel may be performing functions that require regulatory approval or firm certification under the SMCR, without having obtained either, and accountability does not transfer offshore – and the approved UK Senior Manager remains accountable.

In this workshop-style seminar, Browne Jacobson will examine the regulatory and employment issues that arise under the SMCR in the context of visitors, using practical scenarios to illustrate how compliance risk arises and how it can be managed effectively.

Why attend?

Member bank representatives will gain a practical understanding of how the SMCR applies to inbound visits by overseas personnel, and of the steps their firms can take to manage associated conduct risk.

The session will focus on how the SMCR applies to visits by personnel from overseas parent institutions and affiliated entities, and what practical steps firms can take to manage compliance risk on an ongoing basis. It will consider the architecture of the SMCR, how the regime applies differently to branches and subsidiaries of overseas institutions, and the significance of the overall responsibility principle for group structures. The session will also address the development of visitor policies, pre-visit assessment protocols, and the distinction between observational and decision-making participation.

The session will use practical scenarios to ground the discussion in realistic fact patterns, examining how conduct rules obligations and accountability gaps arise in practice – including a conduct rules breach by an overseas employee and the investigation difficulties and jurisdictional complications that follow, and the position of a fly-in, fly-out visitor who undertakes regulated activity or engages in non-financial misconduct in the UK. There will be ample opportunity for open discussion and questions throughout.

Who should attend?

Members of Legal and Compliance functions.

Speakers

Adam Berry, Partner

Adam is a partner at Browne Jacobson, specialising in financial services regulation and investigations. He has over 15 years’ experience – working in private practice, as well as in the Enforcement Division of what is now the Financial Conduct Authority (FCA) and, most recently, in-house at a leading global financial institution.

Adam’s practice consists of defending clients in FCA/Prudential Regulation Authority (PRA) enforcement actions, advising firms in relation to regulatory enquiries, including supervision and authorisation matters, and working on internal investigations. In addition, Adam has considerable experience of working on s.166 Skilled Person reviews – both as a Skilled Person and where clients have been subject to such reviews. Much of Adam’s work consists of advising overseas banks on matters concerning the SMCR, including conduct rule issues.

Raymond Silverstein, Partner

Raymond heads our employment team in the London office which includes immigration advice. Recognised by the Legal 500, Raymond advises a stellar list of private and public sector clients, including financial services, insurers, professional services employers and membership organisations.

Raymond is joint head of the Employment Practices Group in Pangea Net, an international network of law firms Browne Jacobson co-founded.

He advises, mostly employers, on every aspect of employment law, including complex disciplinaries, grievances and claims, reorganisations, relocations, and senior executive exits.

Please note you will receive confirmation of your booking via email within 24 hours. Should you not receive confirmation, please contact AFB to double-check if your booking was successful.

Logistics

Fee: Included in AFB membership

Location: Browne Jacobson, 6 Bevis Marks, London, EC3A 7BA

Date: Wednesday 07 October 2026

Time: 09:00 – 10:30 (Registration, networking and refreshments 08:30 – 09:00)

There will be ample opportunity for questions throughout the session; however, if you would like to submit a question before or have any areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk.

You will receive final event details a week before the event.

Please note that you will only be deemed to have attended (for CPD points) if you have made yourself known at registration and attend 50% or more of the session.