When Safeguarding Goes Wrong, Who Is Personally Responsible?
The Question Most Boards Haven’t Answered Clearly Payment and e-money firms have spent the past nine months preparing for CASS 15. Policies have been written, auditors engaged, reconciliation processes reviewed. But there is one question that often goes unresolved even in well-prepared firms: if the safeguarding framework fails, who is personally accountable? Not the firm. […]