Compliance Monitor
00 status: licence to… exercise SIFs
The FSA’s new significant influence function for parent entities confers what sounds like Bond-like status on its holders – but, alas, glamorous companions and locations are not necessarily part of the package. Richard Burger , Steve Wyndham and Imogen Hurst clarify who and what is involved.
Richard Burger (richard.burger@rpc.co.uk) is a senior associate, Steve Wyndham (steve.wyndham@rpc.co.uk) is an associate and Imogen Hurst (imogen.hurst@rpc.co.uk) is a trainee solicitor in the regulatory group of Reynolds Porter Chamberlain.
Apparently, to gain 00 status, James Bond had to have two confirmed kills while on active service. In comparison the FSA will
confirm 00 status on those simply exercising significant influence functions (SIFs) from a parent company. CF00 status may
be slightly less exciting than holding a licence to kill and sadly there are no gadgets, (although a download of the FSA Handbook
on your iPhone may come in handy). But in a regulated world of ‘credible deterrence’, being a CF00 is just as important.