iCOOC SMF24 Group

Supported by David Blunt and Georgina Philippou, former FCA senior executives, now independent regulatory advisors. For more information contact

In 2023 Armstrong Wolfe established a COO SMF24 group, in response to increasing regulatory expectations and requirements relating to those who hold the SMF24 role.

At quarterly roundtable dinners, hosted by a member of the International COO Community (iCOOC) and facilitated by David and Georgina, as well as at other events, our members have the opportunity to discuss common challenges and identify possible solutions.

An immediate challenge for SMF24s is meeting their regulatory responsibilities relating to operational resilience. The group discussed this in June 2023 and a note of that discussion can be found here, the key themes which emerged related to data, divergence and dependencies – see below – and these will be explored in a forthcoming round table at which we will also pick up key challenges and opportunities, from a COO’s perspective, posed by AI.

volumes; accessibility; reliability

  • Building reliable data sets – and using them to drive decision-making and outcomes
  • Challenges around building trust in data and ensuring the right levels of transparency
  • Measurement, data and reliability challenges relating to DEI and culture
  • Reasonable steps” for SMF24s – moving from record-keeping to evidencing outcomes

UK and international

  • Intra-group and regulatory divergence, locally and internationally
  • SMF24s’ unique role in internal and external stakeholder management
  • COOs and ongoing culture transformation (Op Res and other)

internal and external

  • Outsourcing and oversight of critical 3rd parties
  • Managing internal and external concentration risks, including FMI risks
  • ESG and DEI data challenges
  • SMF24s’ critical stakeholders – e.g. the 2nd line

 “We look forward to working with and supporting our members at SMF24 group fora and dinners throughout the coming period and thank David and Georgina for their continued expert contributions at our events.”

Maurice Evlyn-Bufton, CEO Armstrong Wolfe

David Blunt

David Blunt

Regulatory Advisor: Armstrong Wolfe and iCOOC

“I am an experienced financial services regulatory expert, board level culture and governance specialist and non-executive director. I am highly collaborative and delivery-focused, and an efficient and effective committee chair.

My last role before leaving the FCA in 2022 was head of the Conduct Specialists Department in Supervision as part of the FCA’s Senior Leadership Team and leading the FCA’s strategic priority of transforming culture in financial services – which included extending the SMCR to all authorised firms.

Since leaving the FCA I have pursued a portfolio career of senior advisor and consultancy work to banks and other financial services firms, a non-executive director at the listed issuer RegTech Open Project plc and a trustee for several music charities – as well as doing more violin playing.”

Georgina Philippou

Georgina Philippou

Regulatory Advisor: Armstrong Wolfe and iCOOC

“I am an experienced and well connected professional passionate about public service, diversity and inclusion, and the arts; an energetic and inclusive leader; a strategic thinker and problem solver; a clear and collegiate chair of committees and boards; excellent financial services regulatory knowledge; broad and deep experience of executive and advisory roles.

I am now in the wonderful position of building a portfolio career reflecting my passions: my roles currently include Financial Reporting Council independent Tribunal member; International Monetary Fund Expert Panel; Simmons & Simmons Adaptive Panel; Executive Sponsor of The Diversity Project’s Disability Work Stream; Vice Chair of Ad Centrum, Armstrong Wolfe’s COO DEI initiative, and Citizens Advice Bureau Witness Service volunteer.”