Approved Person Applications and Senior Manager Appointments: Legal Advisory

A GFSO licence is only as usable as the people approved to run it. No individual may perform a Controlled Function for a GFSO Licensed Firm unless approved by the Regulator, three of those functions must be filled at all times by people resident in GMC, and a resignation starts a clock of days and months. Basnet Law advises on Approved Person applications, the mandatory appointments, changes, temporary cover and withdrawals under the General Rulebook.

Map each role to the Controlled Functions in the General Rulebook, from Senior Executive Officer to Responsible Officer.

Plan the mandatory appointments and advise which combinations of roles the Regulator is likely to accept.

Advise on the firm's own fitness and competence assessment before anything is lodged, and keep the six-year record the Rulebook requires.

Advise on the application in the prescribed form and the Regulator's enquiries.

Advise on extensions of scope, conditions, temporary cover and withdrawals.

Advise on the residency requirement and on waiver applications where a Compliance Officer or MLRO will sit outside GMC.

Licence applicants assembling their first management team before the Financial Services Licence issues. Existing Licensed Firms replacing an SEO, Compliance Officer or MLRO. International groups placing a group executive as Responsible Officer over a GMC subsidiary. Individuals who have been asked to take on a Controlled Function.