SM&CR – Accountability 2 – the costs of an “appropriate” response.


So the proposed details of the Accountability 2 regime are out there and firms now at least have some answers regarding proportionality and the levels of requirement that will apply to them. As before the Consultation Papers’ publication – many firms still appear to be focusing on the ‘least case scenario’ i.e. what is the least they can do to get away with it. This has to be a worrying attitude and one that just…

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