The principal objective of the FCA’s CASS Rules is to keep Client Assets safe in the event of a firm’s failure. A fundamental requirement of the CASS Rules is that firms must keep client money separate from firm money in segregated client money bank accounts and register custody assets appropriately. This ensures that client money and custody assets are ring-fenced in the event of the insolvency of the firm.
Ultimately, protecting clients is at the heart of these rules.
CASS has been an FCA priority for the past decade: the regulator has closely scrutinised firms’ arrangements during this time, and has issued multiple fines and public censures for firms and approved individuals alike where compliance has not met the required standards.
Given the ongoing regulatory attention, added to the fact that individuals are more accountable than ever under the Senior Manager and Certification Regime (‘SMCR’), means that this is an optimal time to reassess your compliance arrangements.
How KPMG can help
Starting in the boardroom and working across your entire business, effective CASS management processes and controls need to be embedded into the core of your firm. KPMG can help you understand your requirements and enable you to make confident, well-informed choices that deliver outstanding results.
We have a market-leading team, experienced in working closely with the FCA, who have expertise across all types of organisations and in all areas of CASS operations.
So whether you need help in understanding how CASS impacts your firm, where the FCA is focusing or ways to achieve an enhanced CASS operating model, our team can help.
For more information about our CASS services, contact our team today
Typical projects
We provide a wide range of services to a number of firms in the financial services industry, and always work with our clients to develop a scope that is tailored to their specific requirements. Examples of typical projects we undertake include:
Core Assurance
- Thematic or deep dive reviews including end-to-end control, CASS RP and CMAR reviews
- Assisting compliance and internal audit in either a co-sourced or out-sourced capacity to scope and execute CASS monitoring reviews
CASS Change Projects
- Assisting with driving CASS transformation (e.g. as part of remediation activity / CASS target operating model programmes)
Regulatory Developments
- Individual accountabilities under SMCR
- Changes in the market/industry driven by the FCA, including digital assets regulations
Technology Solutions
- CASS training – design and implementation of computer-based CASS training relevant to your firm’s requirements
Join us for our regular CASS industry forums and Webinars driven by issues faced by clients and latest regulatory developments.
July 2025
CASS: in conversation with the FCA
Watch our on-demand recording where we were joined by Mohammed Safvan Trumboo, CASS Technical Specialist at the FCA. The session explored the FCA’s current areas of focus and observations of industry practices from a regulatory perspective. This was followed by audience Q&A on the key issues driving regulatory intervention in relation to Client Money and Assets.
KPMG CASS 15 Readiness
The introduction of CASS 15 marks a pivotal moment for UK payment and e-money institutions.
KPMG CASS Operating Model
How ready is your firm for a visit from the FCA? At KPMG we can help by simulating a short notice visit from the FCA.
KPMG CASS Health Check
How ready is your firm for a visit from the FCA? At KPMG we can help by simulating a short notice visit from the FCA.
CASS RP Review
The CASS RP is often the starting point for the FCA to see how seriously firms take CASS compliance and whether they properly understand their obligations.
KPMG CASS Training
KPMG have designed multiple training services which we offer to our clients to help them meet their specific training requirements.
Preparing for change: CASS for Payment and E-Money firms
Discussing the practical implications of CASS 15
CP24/20 proposed extending the application of the Client Assets Sourcebook (CASS) rules to payment and e-money firms reflecting the FCA’s commitment to maintaining high standards of consumer protection and financial stability in the evolving financial services landscape. Its aim is to enhance the protection of client funds held by these firms, ensuring they are managed and safeguarded effectively.
KPMG hosted an SME panel broadcast event focusing on the practical next steps firms should take ahead of the final rules being published.
The discussion covered
- The current payments landscape - a summary of the National Payments Vision and the latest from the world of regulation
- The details of the proposed changes to the safeguarding regime, our view on the impact and how to manage the transition.
- Insights into what to expect from the enhanced safeguarding audit standards.
- A lively Q&A session with our panel
Register to watch the full live broadcast event.
The latest instalment of the KPMG CASS SMF Forums were held in London on 30 January 2025 and Edinburgh on 07 February 2025.
Headlines from the event
- Market Updates – An update on the regulator’s current CASS areas of focus and trends in the market.
- Regulatory Changes – an overview of the latest regulatory developments and the impact on CASS.
- Audit observations and current CASS challenges – KPMG observations and key findings from the 2024 cycle along with key CASS challenges we are seeing in the industry.
- Focus on technology risks and controls – an overview of current IT and technology issues we are seeing in the market across our audits and consulting engagements.
- Trusted AI – a discussion on Artificial Intelligence from a CASS perspective and potential opportunities and risks.
There was some interesting and lively discussion in the room and if you wish to revisit the presentations, please find the links below:
Watch our on-demand recording where we were joined by Mohammed Safvan Trumboo, CASS Technical Specialist at the FCA. The session explored the FCA’s current areas of focus and observations of industry practices from a regulatory perspective. This was followed by audience Q&A on the key issues driving regulatory intervention in relation to Client Money and Assets.
It was a pleasure hosting the CASS SMF Forum in person this time around at KPMG’s offices in London and Edinburgh.
There was some interesting and lively discussion in the room and if you wish to revisit the presentation, please find the link below:
Headlines from the event
- Market Updates – an update on the regulator’s current CASS areas of focus and trends in the market.
- Digital Assets – KPMG's view on how the proposed crypto and digital assets regulations will impact CASS requirements and discussing the implications of launching your own Digital Asset.
- Artificial Intelligence – a discussion on Artificial Intelligence in the Banking and Investments space and potential opportunities.
- Spotlight on CASS remediation – key CASS challenges we are seeing in the market, the drivers for transformation and success factors.
- Audit observations - KPMG observations from the 2023 cycle.
We would be happy to pick up further on any of the points covered so please don’t hesitate to reach out.
The latest instalment of the KPMG CASS Webinar series was held on 26 January 2023.
Thank you to all our attendees for making the event a success and for your engagement throughout the session.
For those of you who were unable to join the session, and those who wish to revisit the discussion, we invite you to review the recording and slides of the event by using the link below:
If you would like to discuss any of the themes or if you have any further questions, we would be happy to arrange some time to speak with you about what we are seeing across the industry.
Headlines from the event
- Introduction and market updates – Hanish Arora provided an update on the regulator’s current CASS areas of focus and trends that we are seeing in the market.
- Crypto and Digital assets – Kate Dawson and Ian Taylor discussed KPMG’s views on the evolution of regulation in the Crypto and Digital asset space, as well as how any changes could have a potential impact on the CASS requirements for digital assets.
- Audit observations and current CASS challenges – Alison Allen, Chizoba Uzowuru and John Burton covered KPMG observations and key findings from the 2022 cycle along with key CASS challenges we are seeing in the market.
- Case studies: recent FCA desktop reviews – Rhoda Ejiga provided an overview of recent supervisory activity, including Section 166 reviews and thematic desktop reviews.
Following the success of last summer’s CASS Webinar, we were again thrilled with the turnout and interaction at the latest instalment on 11 February 2021. We were joined by Adrian Smith, Chief Executive at the Reclaim Fund Ltd, who discussed the Dormant Account Scheme.
Please see here for a recording of the event.
In summary, this webinar focussed on the following topics:
- Regulations – Discussing changes to the wider regulatory landscape post Brexit and how this impacts CASS
- Market trends and current CASS challenges – An insight into what KPMG is seeing in the market including challenges which are facing the CASS community
- Dormant Account Scheme – Background to the scheme, what is currently offered and how this is going to be evolving in the future
Please feel free to reach out if you have any questions.
We were delighted to be joined by more than 300 clients for our first ever KPMG CASS webinar. This new format proved to be a success in connecting with our clients whilst we are all working remotely. It was great to hear that CASS remains a priority for the regulator as articulated by our FCA guest speaker - Emad Aladhal. In addition to Emad`s presentation, we also explored topics including CASS market trends and challenges, key Audit observations from 2019 audit cycle and Operational Resilience. The event concluded with an interactive Q&A section between the presenters and the audience – the volume of questions we received truly demonstrated how engaged the audience were.
Please get in touch if you`d like to discuss any of these topics in more detail or are interested in seeing the deck we presented during the webinar.
Our previous CASS Forums were run in February 2020 where we hosted 100+ clients in sessions that were held in Edinburgh and London. The events provided a recap of the CASS market in 2019 and looked ahead to the future of CASS into 2020 and beyond.
Highlights from the recent event included presentations and discussions on:
- The future of UK Financial Services regulation
- SMCR implementation
- Operational Resilience
- Incoming rules on Settlement Discipline under CSDR
- Recent insolvencies
- Evolution of technology within CASS
To ensure that you are invited to any future events, you can register your details and interest by signing up to our CASS Community.
Keep track of our Partner updates published on this page, where we discuss the ways to optimise opportunity in difficult conditions and ensuring your business doesn't fall foul of enhanced regulatory measures.
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