FHDDS51425 - Penalties, sanctions and offences: penalties – policy: Trading without approval - deliberate but not concealed

Trading without approval is deliberate but not concealed if the person

• knows that they are required to be registered

• fails to seek approval at the correct time, but

• does not take active steps to conceal his deliberate failure.

This would include cases where a person has deliberately failed to keep any records of its transactions as opposed to actively concealing or destroying records.