Insurance distribution is the FCA's most enforced accountability terrain.
The structural move is to construct an accountability matrix that names a Senior Manager, equivalent SMF holder, or contractually accountable individual for every customer outcome, every function, and every link in the chain — and that survives senior departures, partner changes, and product redesigns:
The firm maintains a live distribution accountability matrix mapping every entity, function, and Duty outcome across the chain — manufacturer, MGA, broker, comparison site, premium-finance provider, claims TPA, loss assessor — to a named SMF, certified individual, or contractually accountable owner, with seams between parties explicitly named.