This is an illustrative scenario, not a description of a specific FCA enforcement case.
Approved.
Name: Sarah Collins
Time: 14:42
Version: 7
That's the record. A name, a timestamp, a version number. Everything this approval log was built to capture.
One line up, in the same system's version history:
Version 7 — edited by Sarah Collins — 11:20
Same name, both fields. The person who wrote the paragraph is also the person who cleared it for release.
Nothing in the log necessarily flags this. Systems can record who touched what while still allowing one person to control more of the process than intended. A firm reviewing its own history may see a completed workflow without immediately seeing the governance weakness underneath it.
FCA guidance under SYSC 3.2.5 addresses segregation of duties as part of a firm's systems and controls. Its example is transactional: duties should be separated so one individual cannot initiate, process and control the same transaction. The communication scenario is different, but the control question is familiar: how much of one process can one person control alone?
Financial promotion rules add another layer. COBS 4.11 requires firms to make adequate records of financial promotions they communicate or approve. Record-keeping matters, but segregation is a separate control question. An approval history can be perfectly recorded even when the author and approver are the same person.
A wording error, a stale disclosure, a version that should not have gone live: none of these require two people to miss something.
One person missing it, with nobody positioned to catch it, is enough.
With CommsPliant, that separation can be enforced in the workflow itself.
If Sarah creates or edits version seven, she cannot review or approve that same version.
The workflow has to move to somebody else before the communication can progress.
So segregation of duties does not depend on somebody remembering the policy during a busy day.
The control sits inside the process.