Peru: during 2005 we were retained by the FIRST Initiative to work with CONASEV, the Peruvian securities regulator, on improving risk based management in the investment funds sector.   In phase one, we reviewed the areas where fiduciary risk might arise, identifying these and recommending how these should be tackled.  In phase two, policy advice was given on how to amend legal and regulatory requirements and industry and regulatory practice in order to reduce levels of fiduciary risk.