The FCA has published an alert to all Principals, regardless of sector, who have one or more Appointed Representatives or Introducer Appointed Representatives (‘ARs’). Principals are responsible for the regulated activities of their ARs. The alert sets out the risks that the FCA expects firms to consider and act upon, where relevant.
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This is a follow up to previous alerts about the risks involved in dealing with Introcuders. All Principal and Appointed Representative firms should read it.
For information.
New disclosure rules that were intended to take effect from January 2017 have been put back one year.
Does your firm have sufficiently robust systems and controls, policies and procedures and governance in place to mitigate financial crime?
Are you completing your RMAR correctly?
If you have clients with overseas income or assets you might need to notify them of HMRC requirements.
P2P permissions – action required by 31 December 2016
Alistair MacDougall Compliance 2016
If you do not advise on P2P agreements, you need to consider whether you should remove this permission.