Following the Rules

Today’s guest warns that financial services’ boards that place too  much emphasis on compliance risk making their firms less well governed, by crowding out strategic debate and encouraging executives to focus on proving they have ticked the right boxes rather than exercising good judgment.

She also makes the case for preserving the UK’s Senior Managers and Certification Regime, arguing that dismantling it now could ultimately damage the market, even as she calls for parts of the regime to be streamlined.

And, as AI and better data transform both financial firms and their regulators, she considers whether technology could eventually support a simpler rulebook, with greater reliance on judgment and individual accountability.

Sally Dewar’s has spent her 35-year career working across regulation, financial services and corporate governance. A former senior regulator at the Financial Services Authority, she went on to lead international regulatory affairs at JPMorgan Chase before spending six years as CEO of A&O Consulting, the law firm’s regulatory advisory business. Since 2024, she has advised firms, boards and senior executives across the industry, on governance, culture, conduct and regulatory risk as a director at Adelstow Advisory.

The UK crypto industry is approaching a fundamental regulatory shift. Firms that have operated under relatively limited oversight by the UK’s Financial Conduct Authority are preparing to become fully regulated financial services businesses, bringing much broader expectations around governance, consumer protection, capital and conduct.

Today’s episode is part of a Following the Rules series delivering practical guidance on legal, regulatory, technological and cultural change.

In this episode, we explore what the FCA will really be looking for when its crypto authorisation gateway opens, including why using AI to produce policies and controls won’t compensate for senior managers who don’t understand them, and why the FCA’s growth objective will not mean lowering the authorisation bar.

Joining me is Dominic Cashman, the FCA’s Director of Authorisations and one of the people at the heart of determining which firms meet the regulator’s standards for entry. He spent 25 years in senior operational and transformation roles across major financial firms, including TP ICAP, Nomura and Deutsche Bank, before joining the FCA in 2022

We discuss how the FCA will judge whether firms are genuinely ready for regulation, the red flags that can reveal deeper problems with culture and leadership, and why Cashman believes a young crypto industry needs to prepare for the existential crises it has yet to face.

Today’s guest cautions that regulators face a growing gap in understanding and managing the scale and complexity of AI risks and asks whether traditional, technology-neutral regulation can keep pace as adoption accelerates.

He also discusses how Dubai International Financial Centre is weathering conflict in the Middle East. Firms and capital continue to flow into the Centre, but he says that the impact could become more pronounced as businesses reprice a conflict many expected to be short-lived.

And, amid disruption to cloud infrastructure in the region, he discusses operational resilience, technology concentration, and whether regulators themselves fully understand their exposure to critical infrastructure.

Mark Steward is one of the most experienced international regulators of his generation. He previously held senior roles at the Australian Securities and Investments Commission and Hong Kong’s Securities and Futures Commission, before spending seven years at the UK’s Financial Conduct Authority, where he led Enforcement and Market Oversight and latterly also oversaw its International Division.

Since May 2025, he has been Chief Executive of the Dubai Financial Services Authority (DFSA), leading the regulator for one of the world’s fastest-growing financial centres.

He spoke with Following the Rules on 26 August.

Regulation has never been under greater scrutiny. Around the world, governments are asking regulators to support growth and innovation while continuing to protect consumers, preserve financial stability and prevent the next crisis, and increasingly, to do all of it at once, as if the trade-offs between them didn't exist.

Today’s episode is part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change.

Joining me are Lyndon Nelson, former Deputy CEO of the Prudential Regulation Authority and Executive Director at the Bank of England, where he spent more than 30 years in senior regulatory and supervisory roles, and Gavin Stewart, a former senior leader at the Bank of England, the Financial Services Authority and the Financial Conduct Authority, including serving as the FCA's Chief Risk Officer. Together, they are the authors of Building Better Regulators: The Art of the Impossible.

In this episode, we discuss why regulation is fundamentally about managing trade-offs rather than eliminating risk, why regulators remain among the least understood public institutions, and what happens when political pressure demands growth, competitiveness and stability all at once, without acknowledging that something has to give.

Whether you work in regulation, financial services or public policy, this episode offers a practical and timely perspective on what it really takes to build better regulators.

 

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You can pre-order Building Better Regulators: The Art of the Impossible here.

You can play the enforcement game Lyndon mentions here.

Today's episode is a special one, produced in association with Smarsh, a technology firm that helps financial institutions capture, govern and monitor their communications.

This episode forms part of our Following the Rules: How To series, focused on practical guidance for firms navigating legal, regulatory and technological change.

Today we're discussing Smarsh's new 2026 AI Trends Study, conducted by FTI Consulting, which argues that communications data is moving from being a regulatory obligation to one of an organisation's most valuable strategic assets. But it also highlights a growing challenge. While firms are racing to deploy AI, governance is struggling to keep pace. Communications data remains fragmented, shadow AI is creating new blind spots, and many compliance teams are being asked to manage risks they were never designed to oversee.

So what does good AI governance actually look like? How do firms unlock the value of communications data without creating new regulatory risks? And what should compliance leaders be doing now to build the right foundations for AI?

Joining me to discuss this is Goutam Nadella, Chief Strategy Officer at Smarsh. We explore the report's findings, why AI governance starts with data governance, and why the firms that get this right may find compliance becoming a competitive advantage, rather than simply a control function.