CTRL 2.3.1 What is a firm's senior management?

A firm's senior management is made up of—

(a) each individual (if any) who is approved to exercise the following controlled functions for the firm:
(i) the senior executive function;
(ii) the finance function;
(iii) the senior management function;
(iv) the MLRO function;
(v) the risk management function;
(vi) the compliance oversight function;
(vii) the internal audit function;
(viii) the actuarial function; and
(b) any other individual who, together with the individuals in paragraph (a), the Regulatory Authority considers has overall responsibility for the day-to-day management of the part or parts of the firm's business in or from the QFC.

Guidance for para (b)

Depending on the governance and reporting structures for the firm, senior management might include—
•   a person who reports directly to the individual approved to exercise the senior executive function; or
•   a person who oversees the senior executive function; or
•   a person who exercises specific risk functions (for example, credit risk, market risk, liquidity risk and operational risk) and who reports to the individual approved to exercise the risk management function or to the person who heads the group risk management function.
Derived from QFCRA RM/2012-4 (as from 1st July 2013)