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ShareIn serves as a Principal firm with a small network of Appointed Representatives (ARs) and their associated FCA Approved Persons. Whilst ShareIn now falls under the FCA’s Senior Manager & Certification Regime, its Appointed Representatives remain under the Approved Persons Regime.

We are authorised and regulated by the FCA, and ShareIn’s FCA registration number is 603332. Of the FCA regulated activities, ShareIn is permitted to carry on the following:

  • Arranging (bringing about) deals in investments.
  • Arranging safeguarding and administration of assets.
  • Making arrangements with a view to transactions in investments.
  • Agreeing to carry on a regulated activity.

ShareIn may hold client money in connection with the above regulated activities.

ShareIn is not permitted to give investment advice.

Note that given the significant risks investors face when investing in unlisted securities that are difficult to value or sell on a secondary market, the FCA have indicated that such investments can only be promoted to certain types of investor. This is developed further under the section Investor Onboarding below.

In July 2020 ShareIn made the decision that no ShareIn AR should be involved in speculative illiquid securities (SIS). Further information can be found here on SIS

2.1 Compliance Responsibilities and FCA expectations

Primary responsibility for compliance with regulation lies with the senior management of ShareIn and that of each of its Appointed Representatives. The FCA expects firms, through senior management direction, to take a risk-based approach to compliance and focus on preventing material breaches to its principles. Monitoring and other procedures that ensure we comply with our legal and regulatory responsibilities are delegated to the compliance officer.

ShareIn’s SMF16 Compliance Officer is listed on the FCA Register. The compliance officer has day-to-day responsibility for ensuring all FCA activities undertaken by ShareIn meet FCA standards and has a direct reporting line to the management board. The compliance officer undertakes monitoring and other procedures that ensure we comply with our legal and regulatory responsibilities and issues regular reports to the Board.

This does not mean that “compliance” should be seen as a job solely for the Compliance team. Everyday compliance is an integral part of the function of line management and indeed at every level within the business. This “first level of defence” means that ShareIn and its Appointed Representatives can confidently say that being in line with our regulatory requirements is the job of everyone in the firm.

Compliance should be seen as consisting largely of common sense and good business practice. We will develop this further in coming chapters.

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