15. Annual Review of Controls
A Licensed Firm that holds Client Money must implement an annual independent review of the controls over Client Money that were in place over the period from 1 January to 31 December of the preceding year. The review must–
(a) verify the effectiveness of the controls with particular regard to the prevention of –
(ii) misuse, and
(iii) misappropriation of Client Money,
(b) be performed by an appropriate, independent person who may be an internal or external party, and
(c) be delivered to the Registrar by the end of April of each year, for the period covering the preceding year.