The FCA principals for business mandates that a firm under their scrutiny “must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.” (PRIN 2.1.1) and “breaching a Principle makes a firm liable to disciplinary sanctions.” (PRIN 1.1.7).

Merrill Lynch International were fined £49,320,000 in October 2017 because they “contravened Principle 3 of the Authority’s Principles for Businesses by failing to undertake testing to ensure the completeness and accuracy of the reports it was submitting for the purposes of its obligations to report trading in exchange traded derivatives under EMIR” (MLI Final Notice, 2.1.2.2)