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A. Policies and Procedures

1. In addition to all other requirements in the Regulations and Rulebooks, VASPs providing Advisory Services shall establish, implement and enforce appropriate written internal policies and procedures relating to the following—
  a. how they ensure the independent basis of their advice;
  b. how they ensure all Staff providing advice are sufficiently competent in accordance with Rule II.B.1 of this Advisory Services Rulebook; and
  c. such other policies and procedures as VARA may require from time to time.