The buck stops here

You do not mention the size of your firm, but if you have a full-time compliance officer or training officer then you could expect them reasonably to have a grasp of the topic.

One of the major weaknesses we see time and again is the failure to maintain a procedure to retrain or improve the standards of staff members that are found not to be meeting the laid down criteria of the firm.

Any inability to provide the regulator, if asked, with evidence of the firm's approach to maintaining ongoing competence could be regarded as a serious breach, leaving the firm open to a fine or other action.

Many firms place great emphasis on the training of new staff but tend to overlook the ongoing needs of those already at the company. In a regulated environment this is not acceptable and the training needs of all staff members should be covered.

There is a risk that the apparent reduction in size of the T&C rulebook signals to firms that there is less to be done. In fact, it puts more reliance on management and directors to understand the requirements and ensure their implementation.

What you need to do is ensure that your compliance and T&C management understand completely what is required, based on what you have achieved to date. If you are relying on an external consultancy firm then you should ensure that they brief you on the forthcoming changes.

Ultimately, the directors of the firm itself are responsible for implementation.