The Securities and Futures Commission has brought Hong Kong's watered-down version of the UK's Senior Manager Regime fully into force after a six-month transition period.

During that period of transition, about 10,000 people who performed important jobs at licensed corporations were appointed as managers-in-charge. Around 40% of these people are not licensed persons. They are responsible primarily for managing operations or 'control functions' such as compliance, risk management, finance, information technology and money-laundering control.

Under the regime, managers-in-charge of overall management oversight and key business line functions are expected to be (and almost all of them are) 'responsible officers' or ROs. The SFC is still handling RO applications from about 500 managers-in-charge of these two important functions.

The transition period ended on 16 October. On that date, the Hong Kong Monetary Authority issued a circular requiring registered institutions (RIs) (authorised under the Banking Ordinance) to submit up-to-date information about their management structures, along with organisational charts, on email to both the HKMA and the Securities and Futures Commission. To make some time for preparatory work, RIs are expected to report the information between 16 March and 16 April next year. The SFC has updated the relevant 'frequently asked questions' on its website accordingly.