FHDDS51450 - Penalties, sanctions and offences: penalties – policy: Trading without approval - before calculating the penalty

You need to have established:

• the underlying behaviour that gave rise to the failure, for example deliberate and concealed
• whether the disclosure was unprompted or prompted, see FHDDS51525
• the quality of disclosure, see FHDDS51540.

For detailed guidance on how to calculate the penalty please see FHDDS51600.