✔ Companies executing client orders on their own
account equivalent to 0.4% (or more) of the total
average daily volume of a stock over six months will
be expected to register as a Systematic Internaliser.
✔ For bonds, client orders need to be 2.5% or more.
✔ For structured finance, client orders need to
✔ For derivatives, client orders need to be 2.5%
✔ or more.
✔ Firms must have a way of quantifying the level of
risk that they can withstand and draw up policies
identifying key threats.
✔ Firms shall have a risk management function,
which operates independently.
✔ Every year (minimum), risk management team to
produce a report to the ‘management body’, which
also details any corrective actions.
✔ Firms must monitor their exposure to risk and have
a policy to detect any risk of the business failing.
✔ Compliance teams need to operate independently.
✔ Every year (minimum), compliance team to produce
a report to the ‘management body’ on risks
identified from customer complaints.
✔ Compliance teams must be given the ‘necessary
authority’, resources, expertise and access to any
relevant information. It does not stipulate who
decides what is ‘relevant’ information.
✔ Compliance pay and bonuses should not
✔ Firms should have an audit plan, which monitors
systems and controls.
✔ There should be individuals responsible for internal
audit who are separate and independent from other
functions in the business.
✔ Internal audit should issue recommendations in a
report at least every year.