Breaching section 19&23 Fsa Act

Anyone know anything about this. I had some buy to let properties that a friend wanted to invest some money in, which he did, the bang, along came the recession, wiped out all the equity in properties etc and we lost the lot. he,s an unhappy bunny and i now find myself subjected to the wrath of the fsa in relation to it.

Section 19 says you must be authorised to accept money and 23 along the lines of authorised to manage it.

Section 23 says " it is a defence under section 23 for the accused to show that he took all reasonable precautions and exercised all due diligence to avoid committing the offence”.

Put quite simply when i was approached from my friend i sought independant legal advice, solicitor arranged a draft agreement with both parties, issued security to my friend over the properties for the amount of his investment which you would think would suffice.

Fsa now want to take me to task. My question is simple.

Did i take the necessary steps, due dilligence, reasonable precautions and should the lawyer involved be responsible for not making me aware that i had to be authorised for this type of transaction. Fairly serious as there,s a maximum 2 years imprisonment sentence here and the amount my friend lost was £470,000.

Any advice grateful.