Release Date: 31st March 2015
To access the original FCA document, click here.
Summary
Who was fined:
- Robin Farrell, associated with Arch Financial Products LLP (AFP).
Why the FCA fined him:
- The FCA imposed a financial penalty of £650,000 on Robin Farrell for breaches of the Statements of Principle for Approved Persons, specifically Principles 1 (Integrity) and 7 (Compliance with Standards).
- The FCA withdrew Farrell’s approval to perform controlled functions and prohibited him from performing any function related to regulated activities.
- The breaches occurred due to failures in managing conflicts of interest, integrity issues in specific transactions, and inadequate systems for managing non-public information.
Key Takeaways for Other Firms:
- Conflict Management: Ensure robust policies and procedures are in place to manage conflicts of interest. This includes proper identification, mitigation, disclosure, and record-keeping.
- Integrity in Transactions: Act with integrity in all business dealings, especially in transactions involving potential conflicts of interest.
- Systems and Controls: Implement adequate systems for segregating and controlling access to non-public information.
- Leadership Responsibility: Leaders must take an active role in ensuring compliance and managing risks associated with conflicts of interest.
- Audit Trails: Maintain accurate and accessible records of steps taken to manage conflicts to establish a corporate memory and facilitate audit trails.
- Regulatory Compliance: Ensure adherence to FCA Principles for Businesses and Statements of Principle for Approved Persons to avoid regulatory breaches.
By adhering to these principles and ensuring robust systems and controls, firms can mitigate risks and avoid regulatory penalties.
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