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ATCS 7.1 Maintaining effective policies and procedures

ATCS 7.1.1 R

1A designated person who undertakes cash access assessments must:

  1. (1)

    establish, implement and maintain clear and effective policies and procedures:

    1. (a)

      to enable it to undertake cash access assessments in accordance with ATCS 4 and ATCS 5, and reviews under ATCS 9; and

    2. (b)

      setting out the principal factors and criteria it will take into account in undertaking them;

  2. (2)

    set out the policies and procedures in writing;

  3. (3)

    have the policies and procedures approved by its board of directors, committee of management or other governing body, or those persons who effectively direct the business; and

  4. (4)

    publish the policies and procedures in writing in an easily accessible place on its website and keep the published information up to date.

ATCS 7.2 Keeping under review

ATCS 7.2.1 R

A designated person who undertakes cash access assessments must:

  1. (1)

    assess and periodically review:

    1. (a)

      the effectiveness of the policies and procedures referred to in ATCS 7.1.1R, taking into account in particular its own experience and feedback from users of cash access services and other stakeholders; and

    2. (b)

      its compliance with the policies and procedures, and with its obligations under ATCS;

  2. (2)

    in the light of (1), take appropriate measures to address any deficiencies in the policies and procedures, or in its compliance with its obligations; and

  3. (3)

    establish, implement and maintain robust governance arrangements and internal control mechanisms designed to ensure compliance with ATCS 7.

ATCS 7.2.2 R

Where a designated person proposes to update the policies and procedures referred to in ATCS 7.1.1R, it must submit a report to the FCA containing a description of any substantial changes.