Individual requirements
- - Licensed representatives for regulated functions
- - At least two responsible officers for each regulated activity
- - At least one responsible officer available at all times for each regulated activity
- - Executive directors who supervise regulated activity generally need responsible officer approval
People evidence to prepare
- - Role description matched to regulated activities and reporting lines.
- - CV, regulatory history, disciplinary disclosures, exams, and competence evidence.
- - Authority, time commitment, location, backup, and conflict notes.
- - Supervision map showing how the individual controls or escalates regulated work.
- - Public-register verification plan after approval or appointment.
Common bottlenecks
- - Responsible officers without enough authority, availability, local experience, or activity-specific competence
- - Business plans that do not match the regulated activities requested
- - Weak financial resources calculations or unclear custody/client asset model
- - Outsourcing, trading, conflicts, and AML controls drafted generically rather than around the proposed business