4:144 As part of their internal controls, firms should have a holistic, firm-wide risk management framework extending across all business lines and internal units, including independent control functions, one that fully recognises the economic substance of all risk exposures (including environmental and climate-related risks). The risk management framework should enable the firm to make fully informed decisions on risk-taking.

4:145 The risk management framework should also include, pursuant to Articles 68 to 72 of the Brokerage Supervision Act, the following measures related to the management of risks associated with the provision of investment services:

• a record of investment services, investment activities and transactions performed;
• measures to safeguard the rights of customers in order to prevent the use of customer funds for the firm’s own behalf;
• accounting that allows assets held for a specific customer to be distinguished at any time and without delay from those held for other customers and from the firm’s own assets;
• a process to validate financial instruments intended for retail sale,

4:146 For more information on the risk management framework, please see paragraphs 139 to 149 of EBA/GL/2021/14.