The Financial Conduct Authority (FCA) has issued new guidance to companies operating a remote or hybrid working model asking them to provide evidence that any lack of centralised location or remote working does not or is unlikely to affect the company’s ability to meet the threshold for the regulated activities it undertakes.
The guidance states that companies should ensure that when considering any switch from temporary remote working to a permanent situation does not adversely effect consumers, damage the integrity of the market, increase the risk of financial crime or reduce competition.
Other advice contained in the proposals include the need for companies to have the necessary planning in place for a permanent remote working solutions including
- appropriate governance and oversight by senior managers
- control functions such as risk, compliance and internal audits
- the consideration of data, cyber and security risks, particularly as staff may transport confidential material and laptops more frequently in a hybrid arrangement.
Companies are also warned to consider the full legal implications for your business of this type of arrangement and how key functions will be performed, overseen and based. Firms are also advised to manage systems and controls effectively, including digital capabilities such as the ability to access records/systems, whether the firm in question relies on physical documents and what arrangements have been made for their security and access.
You can review the guidance in full here: https://www.fca.org.uk/firms/remote-hybrid-working-expectations
