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Condition 2 – Policies, Procedures and Controls

1. The applicant must establish and maintain compliance arrangements including policies, controls, processes and procedures that ensure and evidence, as far as reasonably practicable, compliance with all regulations, rules, guidance and instructions applicable to it.
2. The applicant must have in place training to communicate those policies, controls and procedures, and any changes to them, to the applicant’s employees.
3. The policies, controls and procedures must include–
(1) risk management,
(2) anti-money laundering, including customer due diligence,
(3) the handling and segregation of client funds and assets,
(4) record keeping, and
(5) the monitoring and management of compliance with, and the internal communication of, such policies, controls and procedures.
4. An applicant must, or upon the grant of a licence will, distinguish between the fees payable:
(a) to the Registrar; and
(b) to the applicant for its services,
in all forms of communication, including the issuing of invoices, relating to any services offered or conducted by the applicant.