Evidencing Reasonable Steps

Evidence of Compliance

Senior Managers may be asked to evidence that they have taken ‘reasonable steps’ under the new regime to prevent or stop breaches within their area of responsibility. It is important that each Senior Manager understands what they and other Senior Managers are responsible for within the firm. Each Senior Manager will want to review their area of responsibility and ensure that they are comfortable with the arrangements and able to evidence that they personally have taken steps to ensure that breaches can be prevented.


Evidencing Reasonable Steps

What you need to do

To evidence this review, we believe senior managers should take a four-stage approach:

  • Verify
    Confirm responsibilities are accurate and understood, updating them where necessary.
  • Diagnose
    Undertake a review of each area of responsibility, the key challenges, areas for improvement, key risks, culture, structure, and governance arrangements in place. 
  • Prioritize
    Risk rate and prioritize the findings and set out plans to address them, escalate if necessary and discuss with relevant parties to develop risk-based responses to issues.
  • Act
    Implement the necessary changes, focusing on sustainable solutions and evidencing systems and controls.