Most sanctions and penalties are levied not because a procedure is wrong, but because a firm does not follow its own procedure, or has no procedure at all.
The risk-based approach. In a nutshell, you must assess where your business is most at risk - in order to plan your mitigation. While some
Well, as regulation evolved, it became apparent that senior managers felt that The Regulations were an issue for the Compliance department, and nothing to do with them. The definition clarifies that if you have a management role, then you have a responsibility.
Short version? If you are in scope, get registered. Pronto. By all means get in touch if you want help or advice. It costs nothing to talk.
While they’re far from perfect, following them, and the guidance that accompanies them, constitutes a defence in court. In short, The Regulations are our friend.