Topic hub
Governance and Decision Defensibility
Boards and executive teams are increasingly expected to show their working, not just their conclusions. When a decision is challenged after the fact, what matters is whether the reasoning, evidence and dissent were properly recorded and tested at the time, not simply whether the outcome was reasonable.
Polar Insight's view
Polar Insight helps leadership teams build decisions that can withstand scrutiny before it happens, by testing evidence quality, capturing genuine challenge, and creating a rationale that holds up under review.
Featured insights
FCA revokes LIBOR bans: enforcement credibility and the cost of relying on criminal convictions
The FCA has revoked bans against four former traders after the Court of Appeal overturned their LIBOR and EURIBOR convictions, closing a decade-long enforcement chapter. For senior leaders, the episode exposes the fragility of regulatory action built on criminal verdicts and reshapes expectations around individual accountability.
Nexus fraud guilty pleas: a £2m lesson in supervising the supervisors
Two senior figures at Nexus IFA and Nexus IM have pleaded guilty to defrauding clients of £2m between 2019 and 2023, with sentencing set for December. The case sharpens questions about director-level accountability, firm permissions, and how boards oversee small advice businesses where control is concentrated.
The FCA opens itself up: a board-level review of how it treats whistleblowers
The FCA has commissioned a board-level review of its handling of a long-standing whistleblower following his death, led by newly appointed non-executive director Lea Paterson. For regulated firms, the signal is that the regulator's own conduct toward vulnerable sources is now a governance matter, with implications for how firms themselves treat internal reporters.
Odey upheld: the Upper Tribunal's integrity finding and what it signals for founder-led firms
The Upper Tribunal has upheld the FCA's ban of Crispin Odey and imposed a £1.53 million fine, finding that he lacked integrity and dismantled his firm's governance to avoid accountability. The ruling reframes non-financial misconduct as a governance failure that boards, not just HR functions, are expected to prevent.
RTGS delay: why the CHAPS standards slip is a governance problem, not a technical one
The Bank of England has deferred the November 2026 RTGS standards release in its entirety after Swift postponed its own CBPR+ release, citing industry concerns about readiness for the removal of unstructured postal addresses. For boards that had budgeted, staffed and sequenced ISO 20022 migration around a fixed November date, the reset is a live test of change governance and vendor accountability.
Dolfin visa scheme: what the £35.5m ban says about SMCR integrity tests
The FCA has fined and banned former Dolfin executives over a scheme that helped at least 99 clients bypass investor visa rules, generating £35.5m in fees. The case resets expectations on shadow control, concealment, and senior manager integrity for boards across wealth and private banking.
Relevant guides
How to Structure an SMCR Handover Certificate That Protects Both Parties
This guide sets out how to build a Senior Manager handover certificate that gives the incoming SMF a fair, complete picture and leaves the outgoing SMF with a defensible record of what they transferred. After reading, you will know what to include, what to evidence, and where handovers typically fail under later supervisory scrutiny.
Writing a Whistleblowing Annual Report That Evidences Real Speak-Up Culture
A practical guide to building a SYSC 18 annual whistleblowing report that goes beyond case counts and demonstrates whether your firm's speak-up culture actually works. Readers will know how to structure the report, what evidence to include, and where boards typically fail to probe.
How to Structure an MLRO Annual Report That Evidences Effective Financial Crime Controls
A practical guide to building an MLRO annual report that gives the board and the FCA genuine assurance on financial crime controls. After reading, you will know how to structure the document, what evidence to include, and where most reports fall short.
Structuring a Consumer Duty Board Report That Evidences Real Outcomes
A practical guide for senior leaders on how to build an annual Consumer Duty board report that demonstrates genuine outcomes monitoring and stands up to supervisory review. Readers will leave with a clear structure, the judgement calls to get right, and the common failure modes to avoid.
How to Structure a SIMR Governance Map That Withstands PRA Challenge
This guide sets out how insurers should build and maintain a Senior Insurance Managers Regime Governance Map that accurately reflects accountability and holds up under ongoing supervisory review. After reading it, you will know what to include, how to sequence updates, and where firms most often lose credibility with the PRA.
How to Allocate Prescribed Responsibilities in an SMCR Statement of Responsibilities
A practical guide to drafting Statements of Responsibilities that allocate Prescribed Responsibilities with precision, avoiding overlap, under-allocation, and the accountability gaps that trigger supervisory concern. Readers will finish with a clear method for mapping PRs to Senior Managers in a way that holds up under scrutiny and reflects how the firm actually operates.