- Proportionate procedures
- Top-level commitment
- Risk Assessment
- Due Diligence on Associated persons/Third Parties
- Training and communication
- Monitoring, review and management information
The guidance also looks at incident management and reporting and gifts and entertaining.
In a well timed op-ed piece, The Drum interviews two lawyers from Sheridans law firm who offer their perspective on why firms should not be concerned about entertaining clients and risking a breach of the UKBA.